HomeMy WebLinkAboutBRIEFING re Draft Right of Way ADA Plan Department of Public Works
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Jefferson County Board of Commissioners
Agenda Request
To: Board of Commissioners
Mark McCauley, County Administrator
From: Monte Reinders, PE, Public Works Director/County Engineer
Agenda Date: December 23, 2024
Subject: Briefing on Draft 2024 Jefferson County Public Right-of-Way
Americans with Disabilities Act (ADA) Transition Plan
Statement of Issue:
Public Works will brief the County Administrator and Board of County Commissioners on the
Draft 2024 Jefferson County Public Right-of-Way Americans with Disabilities Act (ADA)
Transition Plan.
Analysis / Strategic Goals / Pros Ft Cons:
Title II of the Americans with Disabilities Act (ADA) requires that state and local agencies
develop and implement an ADA Transition Plan to identify barriers to accessibility in public
facilities and implement reasonable barrier removal over time in a manner that does not
cause undue financial burden. Public agencies are responsible to address ADA barriers in their
public facilities (buildings, parks, and public right-of-way) as well as their programs, services
and activities. The scope of this Plan addresses curb ramps, sidewalks, driveways, and
pedestrian crossings within the County's public right-of-way as well as select administrative
policies and procedures to meet WSDOT requirements and maintain FHWA funding eligibility.
To remain in compliance with the ADA and as a prerequisite to receiving FHWA funds, WSDOT
is requiring agencies with more than fifty fulltime employees to provide documentation
demonstrating they have started, or completed, an ADA Transition Plan for their public right-
of-way. The Draft 2024 Jefferson County Public Right-of-Way Americans with Disabilities Act
(ADA) Transition Plan is available for public comment from December 17, 2024, through
January 3, 2025. The Final Plan will include revisions based upon any public comments
received and is anticipated to return to the Board of County Commissioners for adoption via
resolution in mid-January 2025.
Fiscal Impact / Cost-Benefit Analysis:
There is no direct cost related to the briefing. Fiscal impact is evaluated through the bi-
annual budgeting process or as urgent requests for ADA accommodation arise.
Recommendation:
Discussion item, no action required.
Department Contact:
Eric Kuzma, 360-385-9167
Reviewed B
Mark McCauley,Ounty Administrator Date
Americans with Disabilities Act (ADA)
ADA Transition Plan for the Public Right-of-Way
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Acknowledgements
Jefferson County wishes to thank the individuals who contributed to this project listed below.
Jefferson County Board of Commissioners
Kate Dean, Commissioner, District 1 (Chair)
Heidi Eisenhour, Commissioner, District 2
Greg Brotherton, Commissioner, District 3
Jefferson County Project Team
Eric Kuzma, Assistant Public Works Director
Connor Ferry, Engineer Tech
Kevin Hitchcock, GIS Coordinator/Administrator
Christine Spall, Public Works Administrative Staff
Chelsie Kilmer, Public Works Administrative Staff
Consultant Team -Transportation Solutions, Inc.
Victor Salemann, Principal Transportation Solutions
Jennifer Salemann, Project Manager '
iaeovnnvr oa a<n .v cUi: raeiF
The Americans with Disabilities Act Notice
In accordance with the requirements of Title II of the Americans with Disabilities Act of 1990
("ADA"), Jefferson County will not discriminate against qualified individuals with disabilities on
the basis of disability in its services, programs, or activities.
ADA/504 Coordinator
The ADA/504 Coordinator is responsible for responding to complaints, grievances, and other
alleged ADA discrimination concerns, as well providing materials in alternative formats. Shawn
Frederick, Jefferson County Central Services Director, is Jefferson County's ADA/504
Coordinator. He can be contacted at:
Phone: 360-385-9362 (Washington Relay System: 7-1-1)
E-mail: SFrederick@co.iefferson.wa.us
Mail: 1820 Jefferson Street, P.O. Box 1120, Port Townsend, WA 98368
Public Right-of-Way (PROW) ADA Coordinator/Official Responsible to Implement Plan
The PROW ADA Coordinator who addresses complaints/grievances specific to the public right-
of-way is Eric Kuzma, Jefferson County Assistant Public Works Director. He is also the official
responsible to implement this PROW ADA Transition Plan. He can be contacted at:
Phone: 360-385-9167 (Washington Relay System: 7-1-1)
E-mail: EKuzma@co.lefferson.wa.us
Mail: Jefferson County Department of Public Works, 623 Sheridan Street, Port Townsend, WA
98368
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Table of Contents
A. Introduction & Legal Requirements........................................................................................... 6
A.1 Legal Precedent..................................................................................................................... 6
A.2 Scope of ADA Transition Plan and Federal Accessibility Requirements............................... 7
A.3 Plan Format and Phased Approach..................................................................................... 11
B. Administrative Policies and Procedures................................................................................... 12
B.1 Official Responsible to Implement the ADA Transition Plan .............................................. 12
B.2 ADA/504 Coordinator and PROW ADA Coordinator........................................................... 12
B.3 Public Notice of ADA Provisions.......................................................................................... 13
B.4 ADA Complaint/Grievance Procedure ................................................................................ 13
B.5 Accessible Pedestrian Signal and Pushbutton (APS) Policy ................................................ 13
C. Public Right-of-Way.................................................................................................................. 14
C.1 Public Right-of-Way Self-Evaluation and Compliance Activities to Date............................ 14
C.2 Public Right-of-Way Barrier Prioritization & Removal Recommendations ........................ 21
C.3 Public Right-of-Way Barrier Removal Cost Estimates......................................................... 29
C.4 Public Right-of-Way Barrier Removal Financial Plan and Schedule.................................... 31
D. Future Actions to Achieve Compliance .................................................................................... 34
D.1 Future Actions Needed....................................................................................................... 34
D.2 Annual Report of ADA Barriers Removed........................................................................... 34
D.3 Five-Year ADA Transition Plan Update Schedule................................................................ 34
E. Public Engagement.................................................................................................................... 35
E.1 Public Engagement Strategy and Findings.......................................................................... 35
E.2 Use of Public Engagement Findings and Recommendations.............................................. 36
F. Accessibility Regulations, Standards & Guidelines Resources.................................................. 37
F.1. Federal ADA Resources ...................................................................................................... 37
F.2 WSDOT Resources............................................................................................................... 37
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
List of Tables
Table C-1. Curb Ramp ADA Compliance (2024)............................................................................ 14
Table C-2. Sidewalk Segment ADA Compliance (2024) ................................................................ 17
Table C-3. Sidewalk Point ADA Compliance (2024) ...................................................................... 17
Table C-4. Jefferson County Curb Ramp Grading System............................................................. 21
Table C-5. Curb Ramp Grade, Condition, and ADA-Compliance Status........................................ 22
Table C-6. Jefferson County Sidewalk and Driveway Grading System ......................................... 24
Table C-7. Sidewalk Grade, Condition, and ADA-Compliance Status........................................... 25
Table C-8. Driveway Grade, Condition, and ADA-Compliance Status .......................................... 26
Table C-9. Curb Ramp Barrier Removal Cost Estimate................................................................. 29
Table C-10. Sidewalk and Driveway Barrier Removal Cost Estimate............................................ 30
Table C-11. Barrier Removal Cost Estimate Summary.................................................................. 30
List of Figures
Figure C-1. Curb Ramp Inventory Map by ADA Compliance (2024)............................................. 15
Figure C-2. Sidewalk and Driveway Inventory Map By ADA Compliance (2024).......................... 19
Figure C-3. Curb Ramps by Grade, Condition, and ADA-Compliance Percentage........................ 22
Figure C-4. Curb Ramps by Grade and Condition Map................................................................. 23
Figure C-5. Sidewalk by Grade, Condition, and ADA-Compliance Percentage............................. 25
Figure C-6. Driveways by Grade, Condition, and ADA-Compliance Percentage .......................... 26
Figure C-7. Sidewalks and Driveways by Grade and Condition Map............................................ 27
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
List of Appendices
Appendix A1— Federal and Washington State Regulations
Appendix A2—WSDOT Local Agency Guidelines and ADA Notice to Local Governments
Appendix Bi—ADA Public Notice
Appendix 11132—ADA Complaint/Grievance Procedure
Appendix 11133—2024 Accessible Pedestrian Signal and Pushbutton (APS) Policy
Appendix C1 - GIS Curb Ramp ADA Inventory and Prioritization
Appendix C2—GIS Sidewalk and Driveway ADA Inventory and Prioritization
Appendix C3—WSDOT Standard Plans for Driveway Interface with Sidewalks
Appendix C4—ADA Barrier Removal Cost Estimates
Appendix C5— DOJ/DOT Joint ADA Curb Ramps Memo and Supplement
Appendix E— Public Engagement Strategy and Findings
List of Abbreviations
ADA—American with Disabilities Act
ADA/504—Americans with Disabilities Act/Section 504 of the Rehabilitation Act of 1973
APS—Accessible Pedestrian Signal
CFR—Code of Federal Regulations (United States)
DWS— Detectable Warning System
FHWA—Federal Highway Administration
GIS—Geographic Information System
LAG — Local Agency Guidelines (published by Washington State Department of Transportation)
MEF— Maximum Extent Feasible
NCHRP— National Cooperative Highways Research Program
PAR— Pedestrian Access Route
PROW—Public Right-of-Way
PROWAG— Public Right-of-Way Accessibility Guidelines (final rule September 7, 2023)
RRFB— Rectangular Rapid Flashing Beacon
USDOJ— United States Department of Justice
USDOT— United States Department of Transportation
WSDOT—Washington State Department of Transportation
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
A. Introduction & Legal Requirements
Jefferson County is committed to removing barriers to accessibility in its public right-of-way
facilities. To achieve this end, the County has completed an Americans with Disabilities Act
(ADA) Transition Plan for the Public Right-of-Way.
This introduction summarizes the legal precedent and the required components of an ADA Self-
Evaluation and Transition Plan. It also provides an overview of the County's Public Right-of-Way
ADA Transition Plan with respect to these requirements.
A.1 Legal Precedent
The following federal laws and local Washington State guidelines informed the content and
scope of this ADA Self-Evaluation and Transition Plan.
A.1.1 Section 504 of the Rehabilitation Act (1973)
Section 504 of the Rehabilitation Act of 1973 states that, "no otherwise qualified individual with
a disability in the United States shall, solely by reason of his or her disability, be excluded from
participation in, denied the benefits of, or be subjected to discrimination under any program or
activity that receives Federal funding."
Section 504 extends to the entire operations of a recipient or assignee, regardless of the
specific funding source of a particular operation. Section 504 Regulations (49 CFR Part 27.5)
define a recipient as, "any [...] public entity [...] to whom Federal financial assistance from the
Department [USDOT] is extended directly or through another recipient, including any successor,
assignee, or transferee thereof." An example of a recipient is WSDOT. An example of an
assignee is Jefferson County as the local agency receiving USDOT funds through WSDOT, for
projects, programs, maintenance, or activities.
A.1.2 American with Disabilities Act
The Americans with Disabilities Act of 1990 is a civil rights statute that prohibits discrimination
against people who have disabilities. There are five separate Titles, or sections, of the Act that
cover different aspects of potential discrimination. These include:
• Title I — Employment
• Title II — Public Services and Transportation
• Title III — Public Accommodations
• Title IV—Telecommunications, and
• Title V— Miscellaneous
Title II of the Act specifically addresses the subject of making public services and public
transportation accessible to those with disabilities. Designing and constructing facilities for
public use that are not accessible by people with disabilities constitutes discrimination.
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
The ADA extends the reach of Section 504 Federal accessibility laws to include agencies that are
not recipients or subrecipients of Federal funding. Title II (28 CFR Part 35) of the ADA
specifically pertains to state and local government agencies.
The ADA applies to all facilities, including both facilities built before and after 1990. State and
local public entities or agencies are required to perform self-evaluations of their current
facilities relative to the accessibility requirements of the current ADA accessibility standards.
The requirements of the ADA apply to all public entities or agencies, no matter the size. The
transition plan formal procedures as outlined in 28 C.F.R. section 35.150 only governs those
public entities with more than 50 employees. For public entities with 50 or less employees, an
access plan includes the same content but is not required to be posted on the agency's website.
A.2 Scope of ADA Transition Plan and Federal Accessibility Requirements
The Federal requirements for preparing and implementing an ADA Transition Plan are outlined
in specific code sections of Title II of the ADA. See Appendix Al.
The 2010 ADA Standards are the current enforceable standard of accessibility requirements for
existing facilities, new construction, and alterations of existing facilities. Given the 2010 ADA
Standards do not cover all elements of the public right-of-way, the U.S. Access Board has been
developing accessibility guidelines for the public right-of-way (PROWAG) that are not yet
enforceable but are considered current best practices.
The County is undertaking this Plan in phases. The scope of the County's ADA Transition
Plan includes curb ramps, sidewalks, and driveways within the County's public right-of-way as
well as select administrative policies and procedures. County buildings and park facilities, and
County programs, services and activities will be evaluated and added in future Phases of the
County's ADA Transition Plan. The County has a 1992 ADA Transition Plan for building and park
facilities that has not since been updated.
A.2.1 Federal ADA Transition/Access Plan Requirements
Under Title II of the ADA, Section 28 CFR Part 35.150 (d) —Transition Plan outlines four
requirements of an ADA Transition Plan. For code text, see Appendix Al.
• Identify physical obstacles in the public entity's facilities that limit the accessibility of its
programs or activities to individuals with disabilities;
• Describe in detail the methods that will be used to make the facilities accessible;
• Specify the schedule for taking the steps necessary to achieve compliance with this
section and, if the time period of the transition plan is longer than one (1) year, identify
steps that will be taken during each year of the transition period; and
• Indicate the official responsible for implementation of the plan.
Note: This Public Right-of-Way ADA Transition Plan addresses physical obstacles in the County's
public right-of-way specific to curb ramps, sidewalks, and driveways.
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
A.2.2 Federal Accessibility Requirements for Existing Facilities
Until the PROWAG is adopted by the USDOJ and USDOT as mandatory, current federal
accessibility requirements for existing public right-of-way facilities are based on the 2010 ADA
Standards (the current enforceable standard). Section 28 § 35.150 of Title II of the ADA
identifies the accessibility requirements for existing facilities. For full code text, see Appendix
Al.
A.2.3 Federal Accessibility Requirements for New Construction or Alterations
Until the PROWAG is adopted by the USDOJ and USDOT as mandatory, current federal
accessibility requirements for new construction and alterations of public right-of-way facilities
are based on the 2010 ADA Standards (the current enforceable standard). Section 28 § 35.151
of Title II of the ADA identifies the accessibility requirements for new construction or
alterations to existing facilities. For full code text, see Appendix Al.
A.2.4 Public Right-of-Way Guidelines (PROWAG)
The U.S. Access Board has been developing guidelines to specifically address accessibility of
sidewalks, shared use paths, crosswalks, curb ramps, pedestrian signals, pedestrian activated
warning devices, at-grade pedestrian rail crossings, on-street parking and other components of
the public right-of-way not addressed by the 2010 ADA Standards. The U.S. Access Board has
made the following progress to finalize these guidelines:
• August 8, 2023—The Board published its final rule in the Federal Register(36 CFR Part
1190).
• As of November 2024, the Board is waiting for the USDOJ and USDOT to adopt the
PROWAG for enforcement under Title II of the ADA with or without modifications.
In this ADA Transition Plan,Jefferson County opted to evaluate its public right-of-way
facilities against the current (2023) PROWAG guidelines instead of the 2010 ADA Standards in
anticipation of adoption of the PROWAG. This Plan also recommends barrier removal based
on compliance with the current version of the PROWAG guidelines as a minimum.
For more information and access to the current version of the PROWAG, visit
https://www.access-board.gov/prowag/.
A.2.5 Washington State Department of Transportation (WSDOT) Local Agency Guidelines
WSDOT's Local Agency Guidelines (LAG) Chapter 29 includes additional ADA Transition Plan
items per Section 504 listed below. For full local agency guidelines text, see Appendix A2.
• Designate an ADA/504 Coordinator
• Maintain Public Notice of ADA Provisions
• Adopt and publish Complaint/Grievance Procedure
• Adopt an Accessible Pedestrian System (APS) Policy
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
In September 2024, WSDOT sent out an ADA Notice to Local Governments to clarify the content
it would look for in ADA Transition Plans and specified a submission date of January 1, 2025, for
local agencies to submit ADA Transition Plans for review. See Appendix A2.
A.2.6 Safe Harbor
Both the Section 504 requirements and 2010 ADA Standards contain a "safe harbor" provision.
However, there is a difference in the timeline associated with the Section 504 safe harbor
provision and the 2010 ADA Standards safe harbor provision. As of April 2024, the PROWAG
does not reference the term "Safe Harbor."
The WSDOT Local Agency Guidelines Chapter 29 provides the following guidance regarding
"Safe Harbor for Alterations" related to the public right-of-way:
"If an agency receives Federal financial assistance from USDOT—either directly or
through another USDOT recipient (such as WSDOT), the agency is subject to the 2004
ADA Accessibility Guidelines (2004 ADAAG).
This became effective in 2006 when the USDOT adopted the 2004 ADA Accessibility
Guideline (2004 ADAAG) into its Section 504 regulations. This document is known as the
2004 ADA Standards. The 2004 Standards have a "safe harbor"provision for curb ramps.
The provision is that if a curb ramps was constructed or altered prior to November 29,
2006, and complies with either the 1991 ADA Standards for Accessible Design (1991 ADA
Accessibility Guidelines) or the Uniform Federal Accessibility Standards (UFAS), it does
not need to be modified as part of a roadway resurfacing project. If this is not the case,
or if the curb ramp is in disrepair then the curb ramp and its detectable warnings
(truncated domes) must shall be brought into compliance with the 2004 Standards) at
the time of an alternation. As mentioned above in Section 29.1, if an agency receives
Federal financial assistance from USDOT—either directly or through another DOT
recipient(such as WSDOT), then the agency is subject to the 2004 ADAAG as part of the
USDOT Section 504 regulations.
For those agencies who are not a recipient or subrecipient of Federal financial assistance
from USDOT, the safe harbor provision in the 2010 ADA Standards for Accessible Design
(2010 Standards) applies. Under the 2010 Standards'safe harbor provision, if curb ramps
were built or altered(in existing facilities)prior to March 15, 2012 and if they comply
with Chapter 29 Section 504 and the Americans with Disabilities Act the 1991 Standards
or the UFAS, they do not need to be modified as part of a resurfacing project.
However, if an existing curb ramp does not comply with either the 1991 Standards or the
UFAS(including if the curb ramp is in a state of disrepair), then the Safe Harbor provision
does not apply and the curb ramp would need to be brought into compliance with the
2010 Standards at the time of roadway alteration.
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
When curb ramps or abutting sidewalks abutting ramps are altered, they shall be
reconstructed to meet the 2010 Standards. For additional curb ramp design guidance,
see LAG manual Chapter 42."'
Safe Harbor was not assumed to apply to any currently deficient ramps in Jefferson County.
Additional research regarding the date of installation and standards met by existing facilities
could be completed at the design stage of future alterations to verify this conclusion. The
existing non-compliant facility could remain in place if it is determined that Safe Harbor applies.
A.2.7 Documentation for Structural Impracticability and Maximum Extent Feasible
The following guidance from the WSDOT Local Agency Guidelines Chapter 29 is useful for
documenting maximum extend feasible decisions:
While ADA/Section 504 regulations do not require documentation of the application of
structural impracticability nor maximum extent feasible, both FHWA and the U.S. Access
Board recommend that these instances be documented so the agency can support its
decisions if challenged at a later date. The documentation of these instances should
reveal the standard of care that guided engineering judgments. While careful
documentation will not protect an agency against complaint, evidence of the
considerations that led to the specific project solution may be persuasive in discussions
with stakeholders or in court.
The following guidance from WSDOT Design Manual M 22-01.22, Chapter 1510 Pedestrian
Facilities, 1510.03(2) Alteration Projects (October 2023, pages 1510-8 to 1510-9) provides
additional guidance for maximum extent feasible documentation:
It may not always be possible to fully meet the applicable accessibility requirements
during alterations of existing facilities.
If such a situation is encountered, consult with the Regional ADA Liaison to develop a
workable solution to meet the accessibility requirements to the maximum extent
feasible. Cost is not to be used as a justification for not meeting the accessibility criteria.
Physical terrain or site conditions that would require structural impacts, environmental
impacts, or unacceptable impacts to the community in order to achieve full compliance
with the accessibility criteria are some of the factors that can be used to determine that
the maximum extent feasible is achieved.
If it is determined to be virtually impossible to meet the accessibility criteria for an
element, document the decision in one of the following ways, as applicable:
• Within the construction impact zone of an alteration project that does not include
reconstruction, realignment, or widening of the roadway, document the following
deficient elements in the DDP:
o Perpendicular curb ramp or parallel curb ramp landing cross slope that is
constrained by the existing roadway gutter profile and exceeds 2% but is less
than or equal to 5% that cannot be constructed to fully meet applicable
accessibility requirements.
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
o Flared side of a perpendicular curb ramp that is constrained by the existing
roadway gutter profile and has a slope that exceeds 10% but is less than or equal
to 16.7% that cannot be constructed to fully meet applicable accessibility
requirements.
• For any deficient element that does not match the preceding description, document
the decision via a stamped and signed Maximum Extent Feasible (MEF) document.
The MEF document will be reviewed by the appropriate Assistant State Design
Engineer(ASDE) and the Headquarters (HQ)ADA Compliance Manager. If
acceptable, the MEF document will be approved and included in the DDP. See Exhibit
300-3 for the approvers of a Maximum Extent Feasible (MEF) document.
For access to the WSDOT Design Manual, visit https://wsdot.wa.gov/engineering-standards/all-
manuals-and-standards/manuals/design-manual.
A.3 Plan Format and Phased Approach
The National Cooperative Highway Research Program (NCHRP) No. 20-7 (232) ADA Transition
Plans:A Guide to Best Practices (May 2009) report demonstrates how the federal ADA
Transition Plan requirements give agencies flexibility on how to format their Transition Plans.
Jefferson County is preparing its ADA Transition Plan in phases across multiple budget years.
The Plan was formatted to accommodate additional chapters for building facilities, parks/trails,
and services/programs/activities to be added in future phases. This first phase of the Transition
Plan addresses components related to accessibility barriers in the County's public right-of-way
and is organized as follows:
• Administrative Policies and Procedures
• Public Right-of-Way
o Self-Evaluation and Compliance Activities to Date
o Barrier Prioritization & Removal Recommendations
o Barrier Removal Schedule and Costs
o Barrier Removal Financial Plan and Schedule
• Public Engagement
• Future Actions to Maintain and Achieve Compliance
• Accessibility Guidelines, Standards, and Resources
• Appendices
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
B. Administrative Policies and Procedures
In 2024, Transportation Solutions, Inc., conducted a self-evaluation inventory of the County's
existing ADA-related administrative policies and procedures identified in the WSDOT LAG
Manual Chapter 29 Checklist and ADA Notice to Local Governments. See Appendix A2.
B.1 Official Responsible to Implement the ADA Transition Plan
The County has designed Eric Kuzma, Asst. Public Works Director, as the official responsible to
implement this ADA Transition Plan. Contact information is provided below and online at
https://co.iefferson.wa.us/1806/PROW-ADA-Transition-Plan
Eric Kuzma, Asst. Public Works Director/Engineering Services Manager
Jefferson County Public Works
623 Sheridan Street
Port Townsend, WA 98368
Phone: 360-385-9167 (Washington Relay System: 7-1-1)
E-mail: EKuzma@co.iefferson.wa.us
B.2 ADA/504 Coordinator and PROW ADA Coordinator
ADA1504 Coordinator
The County has designated Shawn Frederick, Jefferson County Central Services Director, as the
County's ADA/504 Coordinator. Contact information is provided below and online at:
https://co.iefferson.wa.us/1806/PROW-ADA-Transition-Plan
Shawn Frederick, ADA/504 Coordinator and Jefferson County Central Services Director
1820 Jefferson Street.
P.O. Box 1220
Port Townsend, WA 98368
Phone: 360-385-9362 (Washington Relay System: 7-1-1)
E-mail: SFrederick@co.ieferson.wa.us
PROW ADA Coordinator
The County has designated Eric Kuzma, Assistant Public Works Director, as the Public Right-of-
Way (PROW) ADA Coordinator to respond to and address complaints/grievances specific to the
public right-of-way. Contact information is provided below and online at:
https://co.iefferson.wa.us/1806/PROW-ADA-Transition-Plan
Eric Kuzma, PROW ADA Coordinator and Assistant Public Works Director
Jefferson County Department of Public Works
623 Sheridan Street
Port Townsend, WA 98368
Phone: 360-385-9167 (Washington Relay System: 7-1-1)
E-mail: EKuzma@ co.iefferson.wa.us
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
13.3 Public Notice of ADA Provisions
The notice requirement applies to all state and local government agencies covered by Title II,
even localities fewer than 50 employees. The target audience for public notice includes anyone
who may potentially interact with the agency and must be accessible to all. An effective notice
states the basis of what the ADA requires of the public agency in clear, concise language and
should include the name and contact information of the ADA Coordinator. It addresses the
public agency's commitment to non-discrimination on the basis of disability and addresses the
agency's associated policies regarding employment, effective communication, modifications to
policies and procedures, provision of auxiliary aids, scope of the ADA, complaints, and provision
of aid/services at no additional cost. The U.S. Department of Justice's ADA Best Practices Tool
Kit for Local and State Governments provides a template ADA Notice for use by public agencies.
The County has publicly posted its Public Notice of ADA Provisions as part of this ADA Transition
Plan on the County's webpage at https://co.mefferson.wa.us/1806/PROW-ADA-Transition-Plan
and it is provided in Appendix B1.
B.4 ADA Complaint/Grievance Procedure
The County has established an ADA Complaint/Grievance Procedure and record as part of this
ADA Transition Plan and publicly posted its ADA Complaint/Grievance Procedure on the
County's webpage at https://co.iefferson.wa.us/1806/PROW-ADA-Transition-Plan and it is
provided in Appendix B2.
B.S Accessible Pedestrian Signal and Pushbutton (APS) Policy
The County established an APS Policy as part of this ADA Transition Plan and publicly posted it
on the County's webpage at https://co.iefferson.wa.us/1806/PROW-ADA-Transition-Plan and it
is provided in Appendix 63.
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
C. Public Right-of-Way
This chapter describes the County's efforts to address public right-of-way ADA barriers
according to the following steps:
• Self-Evaluation and Compliance Activities to Date
• Barrier Prioritization and Removal Recommendations
• Barrier Removal Schedule and Costs
• Barrier Removal Financial Plan and Schedule
This ADA Transition Plan focuses on curb ramps, sidewalks including driveways, and pedestrian
crossing features. Jefferson County manages 7.3 miles of the non-motorized multi-use Larry
Scott Memorial Trail (a segment of the Olympic Discovery Trail), an additional 0.75 miles of the
Olympic Discovery Trail, and the Rick Tollefson Trail, on all of which the grades were
constructed to current ADA standards. This Plan addresses crossings and termini of these trails
where they intersect the vehicular right-of-way.
CA Public Right-of-Way Self-Evaluation and Compliance Activities to Date
In 2024, existing County curb ramps, sidewalks including driveways, and pedestrian crossing
assets under County jurisdiction were identified and evaluated for their current ADA-
compliance and facility condition.
C.1.1 Curb Ramps
Curb Romp ADA Inventory
In November 2024, field evaluations were performed to collect data on the County's existing
curb ramp assets. Collected field attributes varied by ramp but could include ramp width,
running slope, or cross slope, landing size and slopes, presence of a detectable warning surface,
a photo, and/or additional notes. Each ramp was assigned an ADA compliance status of"Yes"
(ADA-compliant), "No" (not ADA-compliant), or "Other." If one attribute was not compliant, the
curb ramp was assigned a "No" ADA compliance status and is considered an ADA barrier.
Ramps labeled as "Other" are locations along unpaved multi-purpose trail sections that do not
currently have a detectable warning surface (DWS). These are not currently ADA barriers in
their unpaved state, but best practices recommend paving of the trail aprons and installation of
DWS to alert users that they are leaving a pedestrian access route. Of the County's total 122
ramp locations, 88 ramps (72%) are not ADA-compliant with 2023 PROWAG guidelines and 12
(10%) are locations for future DWS to meet best practices. See Table C-1 and Figure C-1.
Table C-1. Curb Ramp ADA Compliance (2024)
ADA Compliance Count
Compliant 22 18%
Non-Compliant 88 72%
Other 12 10%
Total00%
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Figure C-1. Curb Ramp Inventory Map by ADA Compliance (2024)
NMI
.��..:.�
Port Hadlock/Irondale and Chimacum J
Curb Ramp
ADA Compliance
r
♦ • Compliant
■ Non-Compliant
❑ Other(Future DWS Location)
+` — County Roadway Network
f4 " Jefferson County Limits
r•-
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Port Ludlow North
Paradise BaY Rd
IP Cr Or
4- c
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Quilcene Port Ludlow-South
Note: ADA inventory locations along the Larry Scott Memorial Trail and Olympic Discovery Trail are not displayed on the map but are included in
the County's GIS inventory.
15
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
ADA Compliant Curb Ramps
18% of the curb ramps in Jefferson County are ADA-compliant with 2023 PROWAG guidelines.
This is typical for jurisdictions with residential areas built prior to federal adoption of the ADA.
The compliant ramps documented in this inventory are located at:
• Cedar Ave (Port Hadlock/Irondale)
• West Valley Rd (Chimacum Highschool School vicinity)
• Paradise Bay Rd (Port Ludlow intersections with Ebb Tide Ct and Anchor Ln)
ADA Curb Ramp Barrier Summary
72% of the curb ramps in Jefferson County are not compliant with 2023 PROWAG Guidelines.
Notable corridors with non-compliant ramps include:
• Irondale Rd between SR 116 and Matheson St
• Chimacum Rd between Church Ln and SR 116
Approximately half of the non-compliant ramps are at the end of pedestrian access routes that
include asphalt transitions from sidewalks to roadway shoulders of varying steepness and lack
detectable warning surfaces to notify users that they are leaving a pedestrian access route.
These are located in Port Ludlow residential neighborhoods and a few intersections throughout
the County.
The non-compliant curb ramp inventory includes locations on paved trail sections where
detectable warning surfaces are missing but should be provided. The locations that are
currently paved and need detectable warning surfaces to alert users that they are leaving a
pedestrian access route to enter or cross a vehicular roadway include:
• Olympic Discovery Trail between Store Rd and Old Gardiner
• Larry Scott Trail at Nelsons Landing Rd
Other Locations
The remaining 10% of"Other" locations in the curb ramp inventory are places where trail
surface is currently gravel or hard surface up to the paved vehicular roadway and therefore do
not require DWS at this time. To provide consistency for Jefferson County trails and adhere to
best practices for accessibility and safety, it is recommended DWS be installed at these trail
crossing/termini locations:
• Larry Scott Trail at Thomas St, Mill Rd, and S Discovery Rd crossings as well as the Milo
Curry terminus
• Rick Tollefson Trail at east terminus
• Elsie Lopeman Trail recommended at both north and south termini
Jefferson County has marked pedestrian crossings at a handful of intersections and mid-block
crossings that connect paved shoulder to paved shoulder but do not include sidewalks, ramps,
or trails. These locations are not included in the curb ramp inventory since no pedestrian access
route is provided.
16
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
C.1.2 Sidewalks and Driveways
Sidewalk and Driveway ADA Inventory
In November 2024, field evaluations were performed to collect data on the County's existing
sidewalks as well as driveways that intersect sidewalks. Collected field attributes include width,
length, photos, and/or additional notes. The data is provided in GIS format in two ways:
• Sidewalk Segment: Line on the map representing a section of sidewalk. These segments
vary in length and represent a segment of sidewalk between intersecting streets.
• Driveway Point: Point on the map representing a specific driveway along a sidewalk.
Each sidewalk segment and driveway point was assigned an ADA compliance status of"Yes"
(ADA-compliant) or "No" (not ADA-compliant). If one field attribute was not compliant, the
sidewalk spot or segment was assigned a "No" ADA compliance status and is considered an ADA
barrier.
Of the County's sidewalk segments totaling 3.39 miles, 2.95 miles (87%) are not ADA-compliant
with the 2023 PROWAG guidelines. See Table C-2.
Table C-2. Sidewalk Segment ADA Compliance (2024)
# of Total Total Percent
ADA Compliance Segments (Miles) (Feet) Compliant
Compliant 5 0.44 mi 2,345 ft 13%
Non-Compliant I i 15,555 ft 87%
Of the County's 145 driveways along sidewalks, 96% are not ADA-compliant with the 2023
PROWAG guidelines. See Table C-3.
Table C-3. Sidewalk Point ADA Compliance (2024)
ADA Compliance Count Percent Compliant
Compliant 6 4%
Non-Compliant 139 96%
Total11'.
ADA Compliant Sidewalks and Driveways
13% of sidewalks and 4% of the driveways in Jefferson County are ADA-compliant to 2023
PROWAG guidelines. The County's ADA-compliant sidewalks are located at:
• Cedar Ave (Port Hadlock/Irondale)
• Paradise Bay Rd (Port Ludlow)
• West Valley Rd vicinity (Chimacum)
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Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Sidewalk and Driveway Barrier Summary
87% of the sidewalks and 96% of the driveways in Jefferson County are not compliant with
current 2023 PROWAG guidelines. This is typical for jurisdictions with areas built prior to federal
adoption of the ADA.
• The Chimacum Rd/lrondale Rd corridor includes the most severe cross slopes at
driveways (exceeding 10%).
• Center Rd has cross slopes at driveways that slightly exceed 2%.
• Paradise Bay Rd in the north portion of Port Ludlow has sidewalk cross slopes that
slightly exceed 2%.
• Port Ludlow neighborhoods off Paradise Bay Rd and Crestview Dr are older sidewalks
with mostly flush transitions to driveways, however slight upheaval was observed due to
the older age of the sidewalk infrastructure in these neighborhoods.
For a map of Jefferson County's sidewalk segments and driveway points by ADA compliance,
see Figure C-2.
C.1.3 Accessible Pedestrian Signals
As of publication of this Plan in 2024, the County does not have any accessible pedestrian
signals under its jurisdiction.
As part of this ADA Transition Plan, the County is adopting a 2024 Accessible Pedestrian Signal
and Pushbutton (APS) Policy to address future accessible pedestrian signals under County
jurisdiction. See Appendix B3.
C.1.4 Rectangular Rapid Flashing Beacons
As of publication of this Plan in 2024, the County does not have any rectangular rapid flashing
beacons under its jurisdiction.
The County partnered with WSDOT to construct an accessible pedestrian signal crossing SR 116
at Chimacum High School. In November 2024, field observations noted that the pushbuttons
are beyond 10 inch reach from a flat and level landing above the curb ramp.
As part of this ADA Transition Plan, the County is adopting a 2024 Accessible Pedestrian Signal
and Pushbutton (APS) Policy to address future rectangular rapid flashing beacons under County
jurisdiction. See Appendix 83.
C.1.5 Other Public Right-of-Way Barriers
The 2023 PROWAG includes requirements for on-street ADA accessible parking where parking
stalls are marked or metered (R310 On-Street Parking Spaces). The County has no metered or
marked on-street parking stalls and its existing marked parking stalls are not considered on-
street parking as they are located within parking lots associated with building and/or
recreational park facilities. ADA accessible parking at County building and recreational park
facility parking lots will be evaluated at a future phase update to the ADA Transition Plan.
18
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Figure C-2. Sidewalk and Driveway Inventory Map By ADA Compliance (2024)
�,
Port Hadlock/Irondale and Chimacum ,y..
Sidewalk and Driveway
ADA Compliance
" a A Compliant Driveway
4
_ + V Non-Compliant Driveway
Compliant Sidewalk
+ Non-Compliant Sidewalk
' — County Road Network
r r
N Q Jefferson County limits
s
Port Ludlow-North
Paradise
8aV Rd
E,Rose St
i� Quilcene Port Ludlow-South
Note: ADA inventory locations along the Larry Scott Memorial Trail and Olympic Discovery Trail are not displayed on the map but are included in
the County's GIS inventory.
19
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
C.1.6 Safe Harbor and Maximum Extend Feasible
Some non-compliant public right-of-way facilities designed to ADA standards that pre-date the
current 2023 PROWAG guidelines may qualify for Safe Harbor as existing facilities. If that is the
case, the non-compliant facilities could remain in place. However, if an existing facility that
qualifies for Safe Harbor is altered, the curb ramp must be upgraded to meet the current
WSDOT/2023 PROWAG guidelines. WSDOT LAG Manual Chapter 29 includes a section on Safe
Harbor. See Appendix A2.
The inventory work completed in 2024 did not include Safe Harbor assessment but Safe Harbor
candidates are identified below in Section C.2.
C.1.7 Maximum Extend Feasible
Some non-compliant facilities that do not fully meet current 2023 PROWAG guidelines may
qualify for maximum extent feasible (MEF) status if site conditions make meeting the standard
infeasible. See also WSDOT Design Manual Chapter 1510.030(2)Alteration Projects for guidance
on MEF documentation described in Section A.2.7 above.
The inventory work completed in 2024 did not include preparation of maximum extent feasible
documentation. WSDOT LAG Manual Chapter 29 includes a section on documentation for
structural impracticability and MEF. See Appendix A2.
20
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
C.2 Public Right-of-Way Barrier Prioritization & Removal Recommendations
C.2.1 General Barrier Prioritization Recommendations
It is recommended that filed grievances/complaints about barriers to accessibility be
considered high priority for a response and resolution in accordance with the County's adopted
ADA Complaint/Grievance Procedure and other applicable established relevant policies.
It is recommended that prioritization decisions be guided by the overarching principle that
barriers identified and/or experienced by people within the ADA community are of higher
priority for removal than other barriers. Public engagement efforts are therefore a critical
component of the prioritization process.
C.2.2 Curb Ramp Barriers
Curb Ramp Barrier Prioritization
Each curb ramp was assigned a condition (Fair/Better, Poor, Very Poor, Missing, or Other) and
an associated grade (A, B, C, D, or Other). The condition and grade provide a more nuanced
understanding of the County's existing curb ramp inventory. The curb ramp grading system was
developed by the Vermont Department of Transportation (VDOT) and amended for Jefferson
County use. See the grading system in Table C-4.
Table C-4. Jefferson County Curb Ramp Grading System
Grade Ramp Width Detectable Material Condition
Warning Surface
A Fair or Better Condition
GREEN 48" or greater Truncated Dome Limited or tight cracking, faulting (<1/4"),
or isolated spalling
B Exposed Poor Condition
Aggregate Surface
>36"to <48" Moderate cracking, faulting (1/4"-3/4"),
YELLOW or Diamond Shape
or moderate spalling
Stamp
C Very Poor Condition
„ No detectable
36 or less Severe cracking, faulting (>3/4„),
ORANGE warning surface
extensive spalling, or no landing
A curb ramp is needed but does not exist at the location to access an existing
sidewalk (pedestrian access route) where it crosses a curb.
A location at the end of pedestrian access route that includes a transition of
Other varying steepness from the sidewalk to the asphalt roadway shoulder that lacks
WHITE a detectable warning surface to notify users that they are leaving a pedestrian
access route (also for DWS-recommended locations on multi-purpose trails).
21
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Ramps with a grade of A(Fair or Better) may or may not be fully ADA-compliant to current
PROWAG guidelines but are usable in their current form.
Non-compliant grade A (Fair or Better) ramps and grade B (Poor) ramps are usable in their
current form but are not ADA-compliant with current 2023 PROWAG guidelines. These ramps
may meet Safe Harbor for the 2010 ADA Standards (see Section A.2.6). Also, these ramps may
qualify for maximum extent feasible (MEF) status if site conditions make meeting the standard
infeasible. This may be the case for curb ramps located in areas with steep roadway slopes (see
Section A.2.7).
All ramps with a grade of C (Very Poor), or D (Missing) are not ADA-compliant.
Non-compliant ramps with poor or no functionality (grade C or D) are considered higher priority
for barrier removal than non-compliant ramps with higher functionality (grade A and B) or the
"Other" locations where DWS installation would meet best practices for accessibility.
For a table and pie chart of the County's curb ramps by grade, condition, and ADA-compliance,
see Table C-5 and Figure C-3.
For a map of the County's curb ramps by grade and condition, see Figure C-4.
Table C-5. Curb Ramp Grade, Condition, and ADA-Compliance Status
ConditionGrade Percentage ADA Compliant Count Compliance
Grade Percentage
A Fair or Better 39 32% Compliant 22 18%
Non-Compliant 17
B Poor 18 15% Non-Compliant 18
C Very Poor 12 10% Non-Compliant 12 72%
Missing 1 1% Non-Compliant 1
Non-Compliant 40
Other Other 52 43% end of sidewalk
Other on trail 1 12 10%
Figure C-3. Curb Ramps by Grade, Condition, and ADA-Compliance Percentage
Other(on trail)
Other(Non- 10% A Fair or Better(Compliant)
Compliant end of 18%
sidewalk)
33%
A Fair or Better(Non-
D Missing(Non-Compliant) Compliant)
1% 14%
C Very Poor(Non-Compliant) B Poor(Non-Compliant)
14%
10%
22
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Figure C-4. Curb Ramps by Grade and Condition Map
Port Hadlock/Irondale and Chimacum
Curb Ramp Grade
(Condition)
• A(Fair or Better)
` B(Poor)
t x , C(Very Poor)
D(Missing)
o Other
F County Roadway Network
Jefferson County Limits
- Port Ludlow-North
r,.
s-
r
Quilcene Port Ludlow-South
Note: ADA inventory locations along the Larry Scott Memorial Trail and Olympic Discovery Trail are not displayed on the map but are included in
the County's GIS inventory.
23
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Curb Ramp Barrier Removal Recommendations
It is recommended the County:
• Consider removing curb ramp barriers identified by the public through
complaints/grievances or requests per see Section C.2.1.
• Consider removing curb ramp barriers with grade of C (Very Poor) or D (Missing) before
other curb ramp barriers.
• Consider grouping barriers into corridors consistent with the County's Tri-Area Active
Transportation Plan projects to provide cost effective barrier removal, including future
addition of paved aprons and DWS along County multi-purpose trail corridors.
• Monitor the removal of curb ramp barriers in the County's GIS inventory.
The data and GIS prioritization for curb ramps is documented in Appendix C1.
C.2.2 Sidewalk and Driveway Barriers
Sidewalk and Driveway Barrier Prioritization
Sidewalks and driveways were assigned a grade and condition to each asset based on the 2024
field review. The sidewalk and driveway grading system was developed specifically for Jefferson
County use. See the grading system in Table C-6.
Table C-6.Jefferson County Sidewalk and Driveway Grading System
. . -
Sidewalk Condition Driveway Condition
Meets all of the following: • Driveway has cross
• Minimum 48" width slopes within 2 to
• Within 2-2.3% cross slope 2.3%.
A • Running slope matches roadway grade
• Passing zones every 200 feet (not
required if 60" width)
• No obstacles present
One or more of the following applies: • Driveway has flares
• Does not meet minimum 4" width that creates cross
• Cross slope exceeds 2.3%. slopes exceeding 2.3%
• Running slope does not match roadway and less than 10%.
B grade
• No passing zone for 48" width
• Obstacle present (vegetation, fixed
object, upheaval, etc.)
• Minor surface deterioration
Both of the following apply: Driveway has flares
• Meets one or more grade "B" criteria that creates cross
C • Sidewalks with cracks, crumbling surface slopes equal to or
deterioration, or vertical discontinuities. exceeding 10%.
24
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Sidewalks and driveways with a grade of A (Fair or Better) may or may not be fully ADA-
compliant to current PROWAG guidelines but are usable in their current form.
Non-compliant grade A (Fair or Better) or grade B (Poor) sidewalks and driveways may qualify
for Safe Harbor or maximum extent feasible (MEF). See also Sections A.2.6 and A.2.7 above.
All sidewalk assets with a grade of C (Very Poor), or D (Missing) are not ADA-compliant and are
considered higher priority for barrier removal than non-compliant sidewalk assets with higher
functionality (grades A and B).
For a table and pie chart of the County's sidewalks by grade, condition, and ADA-compliance,
see Table C-7 and Figure C-S.
Table C-7. Sidewalk Grade, Condition, and ADA-Compliance Status
Compliance
Percentage Count
Grade Condition Count ADA Compliant Percentage
Grade (Segments)
A Fair or Better 18 44% Compliant 5 13%
Non-Compliant 13
B Poor 13 32% 13
87%C Very Poor 10 24% Non-Compliant 10
Missing 0 0% 0
Figure C-S. Sidewalk by Grade, Condition, and ADA-Compliance Percentage
D Missing(Non-Compliant)
p% A Fair or Better
(Compliant)
12%
C Very Poor(Non-Compliant)
24%
ED
B Poor(Non-Compliant) A Fair or Better(Non-Compliant)
32%
32%
25
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
For a table and pie chart of the County's driveways by grade, condition, and ADA-compliance,
see Table C-8 and Figure C-6.
Table C-8. Driveway Grade, Condition, and ADA-Compliance Status
ConditionGrade Percentage ADA Compliant Count Compliance
Grade Percentage Compliant 6 4%
Fair or Better 129 gg�°
Non-Compliant 123
B Poor 2 1% 2
96%
C Very Poor 14 10% Non-Compliant 14
Missing 0 0% 0
Figure C-6. Driveways by Grade, Condition, and ADA-Compliance Percentage
C Very Poor(Non-Compliant) A Fair or Better(Compliant)
10% 5%
B Poor(Non-Compliant)
1%
A Fair or Better(Non-Compliant)
84%
As shown above, most driveways are considered grade A (Fair or Better) but non-compliant due
to gradual surface deterioration over time. While these are non-compliant, they are still highly
functional and are not considered high priority for barrier removal compared to the grade C
(Very Poor) ramps that are much less functional.
For a map of the County's sidewalks and driveways by grade and condition, see Figure C-7.
26
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Figure C-7. Sidewalks and Driveways by Grade and Condition Map
Port Hadlock/Irondale and Chimacum - �, Sidewalk and Driveway
Grade(Condition)
M
♦ A(Fair or Better)Driveway
V B(Poor)Driveway
;.
77 C(Very Poor)Driveway
— A(Fair or Better)Sidewalk
. 4 B(Poor)Sidewalk
�.
t •�� -- C(Very Poor)Sidewalk
County Road Network
t Q Jefferson County Umits
IRA
� i ✓ 4 ;
►. - ;6
Port Ludlow-North
' '1 Quilcene Port Ludlow-South
Note: ADA inventory locations along the Larry Scott Memorial Trail and Olympic Discovery Trail are not displayed on the map but are included in
the County's GIS inventory.
27
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Sidewalk and Driveway Barrier Removal Recommendations
It is recommended the County:
• Consider removing sidewalk and driveway barriers identified by the public through
complaints/grievances or requests per see Section C.2.1.
• Consider removing sidewalk and driveway barriers with grade of C (Very Poor) before
other sidewalk and driveway barriers.
• Consider grouping barriers into corridors consistent with the County's Tri-Area Active
Transportation Plan projects to provide cost effective barrier removal.
• Monitor the removal of sidewalk and driveway barriers in the County's GIS inventory.
Collected data and GIS prioritization for sidewalk and driveway spot locations and sidewalk
segment locations is documented in Appendix C2.
C.2.3 Accessible Pedestrian Signal (APS) Barriers
APS Barrier Prioritization and Barrier Removal Recommendations
There are no existing accessible pedestrian signals under Jefferson County jurisdiction. Future
APS on roadways under County jurisdiction will be built to the latest WSDOT requirements and
2023 PROWAG guidelines and will be prioritized according to the County's Accessible
Pedestrian Signal Policy.
It is recommended the County:
• Adhere to the adopted APS Policy for future APS installation within County limits under
County jurisdiction.
C.2.4 Rectangular Rapid Flashing Beacon (RRFB) Barriers
RRFB Barrier Prioritization and Barrier Removal Recommendations
There are no existing rectangular rapid flashing beacons (RRFBs) under Jefferson County
jurisdiction, although Jefferson County installed an RRFB crossing on SR 19/Rhody Dr/West
Valley Rd near Chimacum High School. Future RRFBs on roadways under County jurisdiction will
be built to the latest WSDOT requirements and 2023 PROWAG guidelines and will be prioritized
according to the County's Accessible Pedestrian Signal Policy.
It is recommended the County:
• Adhere to the adopted APS Policy for future RRFB installation within County limits under
County jurisdiction.
• Coordinate with WSDOT to install extension arms on both RRFB pushbuttons at the SR
19/Rhody Dr/West Valley Rd crossing to within ten inch reach from level clear space.
C.2.5 Other Public Right-of-Way Barriers
ADA barriers for ADA-accessible parking located at buildings and recreational park facilities will
be addressed at a future update of this ADA Transition Plan. It is recommended these barriers
be prioritized in accordance with the general prioritization criteria established in Section C.2.1.
28
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
C.3 Public Right-of-Way Barrier Removal Cost Estimates
Cost estimates are provided to understand the order of magnitude cost for barrier removal. The
basis of cost estimates were calculated conservatively to account for Jefferson County's rural
context as described in each section below.
C.3.1 Curb Ramp Barrier Removal Cost Estimate
The basis of the cost estimate for curb ramp barriers were calculated conservatively and
includes project administration, preliminary engineering, construction management,
construction cost, and a contingency.
A planning level estimated cost for replacing one curb ramp is $18,500.
In addition to design and construction of the curb ramp itself, additional costs may arise from
addressing issues such as relocation of existing utilities, acquisition of new public right-of-way,
and other roadway improvements such as curb bulbs and new enclosed drainage.
Correcting barriers at blended transitions (near-level transitions at the end of a pedestrian
access route) may cost less than estimated if installation of detectable warning surface is
sufficient to bring the location into compliance. See Table C-9.
Table C-9. Curb Ramp Barrier Removal Cost Estimate
Barrier Type Cost Estimate
Curb ramp (assumes 6-foot wide concrete curb ramp with flared slopes
and yellow truncated dome detectable warning surface) $18,500
C.3.2 Sidewalk and Driveway Barrier Removal Cost Estimate
The basis of cost estimates for sidewalk and driveway barriers were calculated conservatively
and includes project administration, preliminary engineering, construction management,
construction cost, and a contingency.
A planning level estimated cost for replacing one linear foot of 6-foot wide sidewalk is $520 to
$750 (WSDOT requires 6-foot wide sidewalks for new construction in Jefferson County, which
exceeds the 2023 PROWAG's 4-foot wide guideline).
A planning level estimated cost for replacing a driveway with a 20-foot wide ADA-compliant
driveway can range from $27,500 to $31,000 each depending on the chosen design. WSDOT
Standard Plans for multiple types of driveways are provided in Appendix C3 (Design Type 1 is
recommended for Jefferson County). See Table C-10.
29
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Table C-10. Sidewalk and Driveway Barrier Removal Cost Estimate
Sidewalk and Driveway Barrier Type Cost Estimate
6-foot wide sidewalk without drainage per linear foot $520
6-foot wide sidewalk with drainage per linear foot $750
Type 1 Driveway Interface per each (recommended for Jefferson County) $27,500
Type 2 Driveway Interface per each $31,000
Type 3 Driveway Interface per each $27,500
C.3.5 Snow Removal Responsibilities on County/Public Roads
Jefferson County's maintenance department provides snow and ice control on all county roads.
C.3.6 Total Barrier Removal Cost Estimate Summary
The total estimated cost to remove known ADA barriers in Jefferson County is approximately
$15.3 million. See Table C-11.
Table C-11. Barrier Removal Cost Estimate Summary
Barrier Type Total Known Barriers
Curb Ramps
(88 curb ramps x$18,500 per curb ramp) $1,628,000
Sidewalks
(15,555 feet x$635 per linear foot*
(*Average of sidewalk with and without drainage) $9,877,425
Driveways
(139 x $27,500 per Type 1 Driveway) $3,822,500
Total $15,327,925
Cost estimate documentation is provided in Appendix C4.
30
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
C.4 Public Right-of-Way Barrier Removal Financial Plan and Schedule
Jefferson County strives to maximize its transportation funding by using it to leverage state and
federal transportation grant funds. Barrier removal in the right-of-way will typically be included
in these grant funded projects as dedicating transportation funds to non-grant funded projects
severely restricts the Couty's ability to implement projects. General road funds are potentially
available to address urgent requests for accommodation and barrier removal.
The County's Six-Year Transportation Improvement Plan (TIP) will provide for incremental ADA
barrier removal in the public right-of-way in the near term. For more information about the
County's 2025-2030 6-Year Transportation Improvement Program, visit the County's website at
https://www.co.aefferson.wa.us/444/6-Yr-TIP.
Many projects on Jefferson County's 2025-2030 TIP are projects where the County partners
with WSDOT to make improvements to state facilities within Jefferson County. These projects
represent a significant effort by Jefferson County to remove ADA barriers and expand accessible
pedestrian infrastructure in the region, even though the improvements are not on County
facilities. The following Jefferson County 2025-2030 TIP projects that will improve accessibility
on state facilities with ADA-accessible infrastructure include:
Anticipated construction in 2025:
• TIP#1: Quilcene Complete Streets Phase 1: 16 new curb ramps or blended transitions
with DWS, 2 new driveways, and approximately 950' of new 6' wide sidewalk.
• TIP#7: Rhody Drive Ped-Bike Improvements—North Segment: 3 new DWS along multi-
use path extension and approximately 1600' of 8' wide paved multi-use path.
Anticipated construction in 2027:
• TIP#8: Rhody Drive Ped-Bike Improvements—South Segment: 3 new curb ramps with
DWS and approximately 2,450' of new 6' wide sidewalk and an unknown number of
new driveways.
In addition, a top priority of Jefferson County is completion of a multi-use active transportation
network in the Port Hadlock, Chimacum and Irondale Community known as the Tri-Area Active
Transportation Network. The barrier removal plan outlined below recommends to address
barriers in this active transportation network before other barriers in Jefferson County as
funding becomes available. For more information about the Tri-Area Active Transportation
Network, visit the County's website at https://www.co.mefferson.wa.us/441/Jefferson-County-
Multi-Use-Trails.
C.4.1 ADA Barrier Removal on County Facilities
Anticipated removal activities for county facilities for the 2025-2030 time period is$0 due to all
current County funds being obligated to grant funded projects constructing new accessible
pedestrian facilities on WSDOT facilities.
This removal budget may change due to the County's ability to fund TIP projects, which is
subject to annual budget review and reassessment and state/federal grant funding.
31
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
Note: The US DOJ/DOT published a joint technical memo regarding when curb ramp placement
is triggered by resurfacing projects along with a supplement to further clarify the difference
between maintenance activities and alterations. As the County engages in resurfacing activities,
it should keep these requirements for curb ramps in mind. See Appendix C5.
C.4.2 Accessible Pedestrian Signals
The County does not currently own or operate any traffic signals. USDOT requires all agencies
to have an APS Policy to be eligible for federal transportation funding opportunities. As part of
this ADA Transition Plan, the County has adopted an APS Policy.
The County will address requests for APS for areas within County limits under County
jurisdiction according to the County's APS Policy.
C.4.3 Rectangular Rapid Flashing Beacons
The County does not currently own or operate any rectangular rapid flashing beacons (RRFBs).
As part of this ADA Transition Plan,the County has adopted an APS Policy that addresses
rectangular rapid flashing beacons.
The County will address requests for RRFBs for areas within County limits under County
jurisdiction according to the County's APS Policy.
It is recommended the County:
• Partner with WSDOT to install extension arms on the RRFB pushbuttons at the SR
19/Rhody Dr/West Valley Rd crossing so that pushbuttons are within a ten inch reach
from level clear space so people in wheelchairs or mobility devices can reach the
pushbutton.
C.4.4 Other Public Right-of-Way Barriers
Overgrown vegetation, gravel debris, or snow can create temporary accessibility obstacles to
the width, clear space, and surface requirements for pedestrian access routes. It is
recommended County staff perform regular maintenance activities along pedestrian access
routes under its jurisdiction to maintain the greatest degree of accessibility in its public right-of-
way infrastructure.
C.4.5 Near Term Barrier Removal Actions
The total estimated cost to remove known ADA barriers is approximately$15.3 million.
Anticipated barrier removal activities for county facilities for the 2025-2030 time period is $0
due to all current county funds being obligated to grant funded projects constructing new
accessible pedestrian facilities on WSDOT facilities.
32
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
C.4.6 Long Term Barrier Removal Actions
The self-evaluation identified 88 curb ramps barriers, 15,555 lineal feet of sidewalk barriers and
139 driveway barriers. The cost to remove these barriers and provide new accessible facilities is
estimated at $15,327,925.
Based upon the number of new accessible facilities being provided by the current active County
projects on WSDOT facilities in the 2025-2030 6-year period, it is reasonable to assume that in
2031 and onward, the County could on average remove 3 curb ramp barriers, 500-feet of non-
compliant sidewalk barriers, and 5 non-compliant driveway barriers per year on arterials eligible
for state and federal grant funding.
The County should consider replacing non-compliant sidewalks and driveways on low volume
local roads with ADA compliant asphalt shoulders with maximum 2% cross slopes given the
County's limited resources.
The removal of barriers in the public right-of-way for specific accommodation requests should
be addressed; general road funds are potentially available to address these requests so as not to
reduce the County's ability to dedicate road funds to match state and federal grants for
improvements in the public right-of-way.
33
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
D. Future Actions to Achieve Compliance
D.1 Future Actions Needed
This Public Right-of-Way (PROW) ADA Transition Plan addresses self-evaluation, barrier
prioritization, and barrier removal scheduling for existing curb ramp, sidewalk, driveway, and
pedestrian crossing barriers. This Plan establishes the County's accessible pedestrian signal
(APS) policy as well as other policy and procedure requirements.
The County owns/maintains other facility types that will be addressed in the future by other
updates to its existing 1992 ADA Transition Plan for building facilities and parks or other ADA
Transition Plans:
a County buildings with publicly accessible areas and accessible parking
• County park facilities including building structures, restrooms, and recreational areas
• County programs, services, and activities
At a future date, the County will conduct an internal self-assessment, barrier prioritization,
barrier removal cost estimates, and a barrier removal schedule for these facilities and
programming types.
D.2 Annual Report of ADA Barriers Removed
To ensure implementation of this ADA Transition Plan, it is recommended that the County
incorporate an annual review/update process to track ADA self-evaluation and barrier removal
progress for public right-of-way facilities. It is recommended that the official responsible for
implementation of this PROW ADA Transition Plan coordinate this effort in cooperation with
relevant County staff from other departments who are involved with projects that remove ADA
barriers.These annual reports will inform the public every year regarding progress towards ADA
barrier removal and provide a record for County staff to update their asset database
accordingly. Annual reports will be available to the public and posted on the County website at:
htttps://co.mefferson.wa.us/1806/PROW-ADA-Transition-Plan.
D.3 Five-Year ADA Transition Plan Update Schedule
This Plan is intended to be reviewed and updated at five-year intervals. As the Plan is updated,
an updated barrier removal schedule will be identified. With each five-year Plan update, an
official public comment period is recommended to continue public engagement. The
inventories and cost estimates will be re-analyzed at each five-year Plan update to determine
patterns of need as it relates to the complete facility inventory and barrier removal
prioritization.
34
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
E. Public Engagement
E.1 Public Engagement Strategy and Findings
The County's public engagement strategy included digital announcements and opportunities for
the general public to comment on the Plan. The County webpage, Board of Commissioner
meeting, and public comment period provided accessible methods of public participation. The
findings are helpful in guiding County staff in the selection and prioritization of barrier removal.
For documentation, see Appendix E.
E.1.1 County Webpage and Web-Based Publications
The project webpage content launched in November 2024 and is available at:
https://co.wefferson.wa.us/1806/PROW-ADA-Transition-Plan
The webpage includes the following:
• Project Description
• County Staff Contacts for ADA/504 Coordinator and PROW ADA Coordinator/Official
Responsible to Implement the Plan
• Project Schedule
• Other ADA Resources section with associated links
• Public Engagement Opportunities section with County Board of Commissioner
Workshop meeting information for Draft Plan presentation and public comment
• Documents section for posting draft version for public comment and final version
• Recent Accomplishments section for further tracking of ADA Transition Plan
implementation progress.
The following digital publications promoted the project and public comment opportunities:
• Jefferson County News Flash: December## and ##
• Social Media Posts: December## and ##
o Jefferson County Government Facebook® page
o Jefferson County Public Health Facebookm page
o Jefferson County Public Works Instagram® page
E.1.2 Direct Engagement with Local Community Organizations
County staff contacted following local community organizations and institutions via direct e-
mail in December 2024, to request their support to promote the Draft ADA Transition Plan
comment period through their communication channels:
• Jefferson County Library District Branches
• Port Townsend, Chimacum and Quilcene School Districts
• Olympic Area Agency on Aging— Port Townsend Office
35
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
• Jefferson County Chamber of Commerce
• Port Ludlow Voice (Community newspaper)
• Tri-Area, Gardiner, Quilcene, and Brinnon Community Centers
• OlyCAP (Olympic Community Action Programs)
E.1.3 Public Comment Opportunities
The Draft Public Right-of-Way ADA Transition Plan was posted online for public comment
December##through ##, 2024.
# public comments were received via email or on social media platforms on the Draft ADA
Transition Plan.
The Draft ADA Transition Plan was presented to the Jefferson County Board of Commissioners
on Month Day, 2024, during their 9:OOam meeting on the Zoom® platform; refer to the
Jefferson County Board of Commissioners workshop agenda, and minutes on Jefferson County's
webpage for this content:
https://www.co.eefferson.wa.us/492/Board-of-County-Commissioners
Presentation materials were provided in accessible formats with alternative text prior to the
event. The presentation explained the reasons for and required content of an ADA Transition
Plan and the County's phased approach to self-evaluation and barrier removal implementation
focused first on curb ramps, sidewalks, driveways, and accessible pedestrian crossings within
the public right-of-way. An open comment opportunity followed the presentation.
# public comments were received at the County Board of Commissioner workshop meeting. For
meeting presentation documentation, see Appendix E.
E.2 Use of Public Engagement Findings and Recommendations
It is recommended the County:
• Utilize the Jefferson County ADA Transition Plan project webpage as a tool for on-going
ADA Transition Plan barrier removal progress updates.
36
Jefferson County 2024 Public Right-of-Way ADA Transition Plan
F. Accessibility Regulations, Standards & Guidelines Resources
This Plan is based on the most recent federal and state regulations, standards, and guidelines.
F.1. Federal ADA Resources
F.1.1 ADA Title II Regulations (28 CFR Part 35)
https://www.ada.gov/regs2010/titlell 2010/titlell 2010 regulations.htm
F.1.2 U.S.Access Board
Public Rights-of-Way Accessibility Guidelines (2023 PROWAG)
https://www.access-board.gov/prowag/
U.S. Access Board DOJ ADA Accessibility Standards (2010)
https://www.access-board.gov/guidelines-and-standards/buildings-and-sites/about-the-ada-
standards/ada-standards
F.1.3 U.S. Department of Justice
U.S. DOJ ADA Best Practices Tool Kit for State and Local Governments
https://www.ada.gov/pcatoolkit/toolkitmain.htm
ADA Title 11 Technical Assistance Manual
https://www.ada.gov/taman2.html
F.1.4 Federal Highway Administration
FHWA's Interim Approval 21 Pedestrian-Actuated Rectangular Rapid-Flashing Beacons
https://mutcd.fhwa.dot.gov/res-interim approvals.htm
F.2 WSDOT Resources
Letter to Local Agencies Regarding ADA Transition Plans (September 2024)
https://wsdot.wa.gov/about/disability-access-concerns-ada
Local Agency Guidelines: Chapter 29 Section 504 of the Americans with Disabilities Act
https://www.wsdot.wa.gov/Publications/Manuals/M36-63.htm
WSDOT Design Manual
https://wsdot.wa.gov/engineering-standards/all-manuals-and-standards/manuals/design-
manual
WSDOT ADA Field Guide (2012 PROWAG)
https://wsdot.wa.gov/engineering-standards/all-manuals-and-standards/manuals/ada-field-
guide-accessible-public-rights-way
37
Public Right-of-Way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
ON
J r-y
1z,�/i
1 J` J \Y
Appendix Al
Federal Accessibility Requirements Documentation
December 2024
Prepared by
Transportation Solutions
INNOVATIVE ( PRACTICAL I EQUITABLE
A.2.1 Federal ADA Transition Plan Requirements—Full Regulation Text
Under Title II of the ADA, Section 28 CFR Part 35.150 (d) - Transition plan outlines the
requirements of an ADA Transition Plan:
(1) In the event that structural changes to facilities will be undertaken to achieve program
accessibility, a public entity that employs 50 or more persons shall develop, within six months
of January 26, 1992, a transition plan setting forth the steps necessary to complete such
changes. A public entity shall provide an opportunity to interested persons, including
individuals with disabilities or organizations representing individuals with disabilities, to
participate in the development of the transition plan by submitting comments. A copy of the
transition plan shall be made available for public inspection.
(2) If a public entity has responsibility or authority over streets, roads, or walkways, its
transition plan shall include a schedule for providing curb ramps or other sloped areas where
pedestrian walks cross curbs, giving priority to walkways serving entities covered by the Act,
including State and local government offices and facilities, transportation, places of public
accommodation, and employers, followed by walkways serving other areas.
(3) The plan shall, at a minimum—
(i) Identify physical obstacles in the public entity's facilities that limit the accessibility of
its programs or activities to individuals with disabilities;
(ii) Describe in detail the methods that will be used to make the facilities accessible;
(iii) Specify the schedule for taking the steps necessary to achieve compliance with this
section and, if the time period of the transition plan is longer than one year, identify
steps that will be taken during each year of the transition period; and
(iv) Indicate the official responsible for implementation of the plan.
(4) If a public entity has already complied with the transition plan requirement of a Federal
agency regulation implementing section 504 of the Rehabilitation Act of 1973, then the
requirements of this paragraph (d) shall apply only to those policies and practices that were not
included in the previous transition plan.
A.2.2 Federal Accessibility Requirements for Existing Facilities—Full Regulation Text
Section 28 § 35.150 of Title II of the ADA identifies the accessibility requirements for existing
facilities:
(a) General. A public entity shall operate each service, program, or activity so that the service,
program, or activity, when viewed in its entirety, is readily accessible to and usable by
individuals with disabilities. This paragraph does not -
(1) Necessarily require a public entity to make each of its existing facilities accessible to
and usable by individuals with disabilities;
1
(2) Require a public entity to take any action that would threaten or destroy the historic
significance of an historic property; or
(3) Require a public entity to take any action that it can demonstrate would result in a
fundamental alteration in the nature of a service, program, or activity or in undue
financial and administrative burdens. In those circumstances where personnel of
the public entity believe that the proposed action would fundamentally alter the
service, program, or activity or would result in undue financial and administrative
burdens, a public entity has the burden of proving that compliance with § 35.150(a) of
this part would result in such alteration or burdens. The decision that compliance would
result in such alteration or burdens must be made by the head of a public entity or his or
her designee after considering all resources available for use in the funding and
operation of the service, program, or activity, and must be accompanied by a written
statement of the reasons for reaching that conclusion. If an action would result in such
an alteration or such burdens, a public entity shall take any other action that would not
result in such an alteration or such burdens but would nevertheless ensure that
individuals with disabilities receive the benefits or services provided by the public entity.
(b) Methods-
(1) General. A public entity may comply with the requirements of this section through
such means as redesign or acquisition of equipment, reassignment of services to
accessible buildings, assignment of aides to beneficiaries, home visits, delivery of
services at alternate accessible sites, alteration of existing facilities and construction of
new facilities, use of accessible rolling stock or other conveyances, or any other
methods that result in making its services, programs, or activities readily accessible to
and usable by individuals with disabilities. A public entity is not required to make
structural changes in existing facilities where other methods are effective in achieving
compliance with this section. A public entity, in making alterations to existing buildings,
shall meet the accessibility requirements of§ 35.151. In choosing among available
methods for meeting the requirements of this section, a public entity shall give priority
to those methods that offer services, programs, and activities to qualified individuals
with disabilities in the most integrated setting appropriate.
(2)
(i) Safe harbor. Elements that have not been altered in existing facilities on or
after March 15, 2012 and that comply with the corresponding technical and
scoping specifications for those elements in either the 1991 Standards or in the
Uniform Federal Accessibility Standards (UFAS), Appendix A to 41 CFR part 101-
19.6 (July 1, 2002 ed.), 49 FR 31528, app. A (Aug. 7, 1984) are not required to be
modified in order to comply with the requirements set forth in the 2010
Standards.
2
(ii) The safe harbor provided in § 35.150(b)(2)(i) does not apply to those
elements in existing facilities that are subject to supplemental requirements (i.e.,
elements for which there are neither technical nor scoping specifications in the
1991 Standards). Elements in the 2010 Standards not eligible for the element-by-
element safe harbor are identified as follows—
(A) Residential facilities dwelling units, sections 233 and 809.
(B)Amusement rides, sections 234 and 1002; 206.2.9; 216.12.
(C) Recreational boating facilities, sections 235 and 1003; 206.2.10.
(D) Exercise machines and equipment, sections 236 and 1004; 206.2.13.
(E) Fishing piers and platforms, sections 237 and 1005; 206.2.14.
(F) Golf facilities, sections 238 and 1006; 206.2.15.
(G) Miniature golf facilities, sections 239 and 1007; 206.2.16.
(H) Play areas, sections 240 and 1008; 206.2.17.
(1)Saunas and steam rooms, sections 241 and 612.
(J) Swimming pools, wading pools, and spas, sections 242 and 1009.
(K) Shooting facilities with firing positions, sections 243 and 1010.
(L) Miscellaneous.
(1) Team or player seating, section 221.2.1.4.
(2) Accessible route to bowling lanes, section 206.2.11.
(3) Accessible route in court sports facilities, section 206.2.12.
(3) Historic preservation programs. In meeting the requirements of§35.150(a) in historic
preservation programs, a public entity shall give priority to methods that provide
physical access to individuals with disabilities. In cases where a physical alteration to an
historic property is not required because of paragraph (a)(2) or (a)(3) of this section,
alternative methods of achieving program accessibility include -
(i) Using audio-visual materials and devices to depict those portions of an historic
property that cannot otherwise be made accessible;
(ii) Assigning persons to guide individuals with handicaps into or through
portions of historic properties that cannot otherwise be made accessible; or
(iii) Adopting other innovative methods.
(4) Swimming pools, wading pools, and spas. The requirements set forth in sections 242
and 1009 of the 2010 Standards shall not apply until January 31, 2013, if a public
3
entity chooses to make structural changes to existing swimming pools, wading pools, or
spas built before March 15, 2012, for the sole purpose of complying with the program
accessibility requirements set forth in this section.
(c) Time period for compliance. Where structural changes in facilities are undertaken to comply
with the obligations established under this section, such changes shall be made within three
years of January 26, 1992, but in any event as expeditiously as possible.
(d) Transition plan. [See Section A.2.1 for regulation text.]
A.2.3 Federal Accessibility Requirements for New Construction or Alterations- Full Regulation
Text
Section 28 § 35.151 of Title II of the ADA identifies the accessibility requirements for new
construction or alterations to existing facilities:
§ 35.151 New construction and alterations.
(a) Design and construction.
(1) Each facility or part of a facility constructed by, on behalf of, or for the use of a public
entity shall be designed and constructed in such manner that the facility or part of
the facility is readily accessible to and usable by individuals with disabilities, if the
construction was commenced after January 26, 1992.
(2) Exception for structural impracticability.
(i) Full compliance with the requirements of this section is not required where
a public entity can demonstrate that it is structurally impracticable to meet the
requirements. Full compliance will be considered structurally impracticable only
in those rare circumstances when the unique characteristics of terrain prevent
the incorporation of accessibility features.
(ii) If full compliance with this section would be structurally impracticable,
compliance with this section is required to the extent that it is not structurally
impracticable. In that case, any portion of the facility that can be made
accessible shall be made accessible to the extent that it is not structurally
impracticable.
(iii) If providing accessibility in conformance with this section to individuals with
certain disabilities (e.g., those who use wheelchairs) would be structurally
impracticable, accessibility shall nonetheless be ensured to persons with other
types of disabilities, (e.g., those who use crutches or who have sight, hearing, or
mental impairments) in accordance with this section.
(b)Alterations.
4
(1) Each facility or part of a facility altered by, on behalf of, or for the use of a public
entity in a manner that affects or could affect the usability of the facility or part of
the facility shall, to the maximum extent feasible, be altered in such manner that the
altered portion of the facility is readily accessible to and usable by individuals with
disabilities, if the alteration was commenced after January 26, 1992.
(2) The path of travel requirements of§ 35.151(b)(4) shall apply only to alterations
undertaken solely for purposes other than to meet the program accessibility
requirements of§ 35.150.
(3)
(i) Alterations to historic properties shall comply, to the maximum extent
feasible, with the provisions applicable to historic properties in the design
standards specified in § 35.151(c).
(ii) If it is not feasible to provide physical access to an historic property in a
manner that will not threaten or destroy the historic significance of the building
or facility, alternative methods of access shall be provided pursuant to the
requirements of§ 35.150.
(4) Path of travel. An alteration that affects or could affect the usability of or access to
an area of a facility that contains a primary function shall be made so as to ensure that,
to the maximum extent feasible, the path of travel to the altered area and the
restrooms, telephones, and drinking fountains serving the altered area are readily
accessible to and usable by individuals with disabilities, including individuals who use
wheelchairs, unless the cost and scope of such alterations is disproportionate to the
cost of the overall alteration.
(i) Primary function. A "primary function" is a major activity for which the facility
is intended. Areas that contain a primary function include, but are not limited to,
the dining area of a cafeteria, the meeting rooms in a conference center, as well
as offices and other work areas in which the activities of the public entity using
the facility are carried out.
(A) Mechanical rooms, boiler rooms, supply storage rooms, employee
lounges or locker rooms,janitorial closets, entrances, and corridors are
not areas containing a primary function. Restrooms are not areas
containing a primary function unless the provision of restrooms is a
primary purpose of the area, e.g., in highway rest stops.
(B) For the purposes of this section, alterations to windows, hardware,
controls, electrical outlets, and signage shall not be deemed to be
alterations that affect the usability of or access to an area containing a
primary function.
(ii) A "path of travel' includes a continuous, unobstructed way of pedestrian
passage by means of which the altered area may be approached, entered, and
5
exited, and which connects the altered area with an exterior approach (including
sidewalks, streets, and parking areas), an entrance to the facility, and other parts
of the facility.
(A) An accessible path of travel may consist of walks and sidewalks, curb
ramps and other interior or exterior pedestrian ramps; clear floor paths
through lobbies, corridors, rooms, and other improved areas; parking
access aisles; elevators and lifts; or a combination of these elements.
(B) For the purposes of this section, the term "path of travel" also
includes the restrooms, telephones, and drinking fountains serving the
altered area.
(C)Safe harbor. If a public entity has constructed or altered required
elements of a path of travel in accordance with the specifications in
either the 1991 Standards or the Uniform Federal Accessibility Standards
before March 15, 2012, the public entity is not required to retrofit such
elements to reflect incremental changes in the 2010 Standards solely
because of an alteration to a primary function area served by that path of
travel.
(iii) Disproportionality.
(A) Alterations made to provide an accessible path of travel to the altered
area will be deemed disproportionate to the overall alteration when the
cost exceeds 20% of the cost of the alteration to the primary function
area.
(B) Costs that may be counted as expenditures required to provide an
accessible path of travel may include:
(1) Costs associated with providing an accessible entrance and an
accessible route to the altered area, for example,the cost of widening
doorways or installing ramps;
(2) Costs associated with making restrooms accessible, such as installing
grab bars, enlarging toilet stalls, insulating pipes, or installing accessible
faucet controls;
(3) Costs associated with providing accessible telephones, such as
relocating the telephone to an accessible height, installing amplification
devices, or installing a text telephone (TTY); and
(4) Costs associated with relocating an inaccessible drinking fountain.
(iv) Duty to provide accessible features in the event of disproportionality.
6
(A) When the cost of alterations necessary to make the path of travel to
the altered area fully accessible is disproportionate to the cost of the
overall alteration, the path of travel shall be made accessible to the
extent that it can be made accessible without incurring disproportionate
costs.
(B) In choosing which accessible elements to provide, priority should be
given to those elements that will provide the greatest access, in the
following order-
(1) An accessible entrance;
(2) An accessible route to the altered area;
(3) At least one accessible restroom for each sex or a single unisex
restroom;
(4) Accessible telephones;
(5) Accessible drinking fountains; and
(6) When possible, additional accessible elements such as parking,
storage, and alarms.
(v) Series of smaller alterations.
(A) The obligation to provide an accessible path of travel may not be
evaded by performing a series of small alterations to the area served by a
single path of travel if those alterations could have been performed as a
single undertaking.
(B)
(1) If an area containing a primary function has been altered
without providing an accessible path of travel to that area, and
subsequent alterations of that area, or a different area on the
same path of travel, are undertaken within three years of the
original alteration, the total cost of alterations to the primary
function areas on that path of travel during the preceding three
year period shall be considered in determining whether the cost
of making that path of travel accessible is disproportionate.
(2) Only alterations undertaken on or after March 15, 2011 shall
be considered in determining if the cost of providing an accessible
path of travel is disproportionate to the overall cost of the
alterations.
(c)Accessibility standards and compliance date.
(1) If physical construction or alterations commence after July 26, 1992, but prior to
September 15, 2010, then new construction and alterations subject to this section must
comply with either UFAS or the 1991 Standards except that the elevator exemption
contained at section 4.1.3(5) and section 4.1.6(1)(k) of the 1991 Standards shall not
apply. Departures from particular requirements of either standard by the use of other
methods shall be permitted when it is clearly evident that equivalent access to
the facility or part of the facility is thereby provided.
(2) If physical construction or alterations commence on or after September 15, 2010 and
before March 15, 2012, then new construction and alterations subject to this section
may comply with one of the following: The 2010 Standards, UFAS, or the 1991 Standards
except that the elevator exemption contained at section 4.1.3(5) and section 4.1.6(1)(k)
of the 1991 Standards shall not apply. Departures from particular requirements of either
standard by the use of other methods shall be permitted when it is clearly evident that
equivalent access to the facility or part of the facility is thereby provided.
(3) If physical construction or alterations commence on or after March 15, 2012, then
new construction and alterations subject to this section shall comply with the 2010
Standards.
(4) For the purposes of this section, ceremonial groundbreaking or razing of structures
prior to site preparation do not commence physical construction or alterations.
(5) Noncomplying new construction and alterations.
(i) Newly constructed or altered facilities or elements covered by §§ 35.151(a) or (b)
that were constructed or altered before March 15, 2012, and that do not comply
with the 1991 Standards or with UFAS shall before March 15, 2012, be made
accessible in accordance with either the 1991 Standards, UFAS, or the 2010
Standards.
(ii) Newly constructed or altered facilities or elements covered by §§ 35.151(a) or (b)
that were constructed or altered before March 15, 2012 and that do not comply
with the 1991 Standards or with UFAS shall, on or after March 15, 2012, be made
accessible in accordance with the 2010 Standards.
Appendix to 35.151(c)
Compliance Date for
Construction or •
Before September 15, 2010 1991 Standards or Uniform Federal
Accessibility Standards (UFAS)
On or after September 15, 2010, 1991 Standards, UFAS, or 2010 Standards
and before March 15, 2012
On or after March 15, 2012 2010 Standards
(d) Scope of coverage. The 1991 Standards and the 2010 Standards apply to fixed or built-in
elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways
8
located on a site. Unless specifically stated otherwise, the advisory notes, appendix notes, and
figures contained in the 1991 Standards and the 2010 Standards explain or illustrate the
requirements of the rule; they do not establish enforceable requirements.
(e) Social service center establishments. [See full regulations.]
(f) Housing at a place of education. [See full regulations.]
(g)Assembly areas. [See full regulations.]
(h) Medical care facilities. [See full regulations.]
(i) Curb ramps.
(1) Newly constructed or altered streets, roads, and highways must contain curb ramps
or other sloped areas at any intersection having curbs or other barriers to entry from a
street level pedestrian walkway.
(2) Newly constructed or altered street level pedestrian walkways must contain curb
ramps or other sloped areas at intersections to streets, roads, or highways.
0) Facilities with residential dwelling units forsale to individual owners. [See full regulations.]
(k) Detention and correctional facilities.
(1) New construction of jails, prisons, and other detention and correctional facilities
shall comply with the 2010 Standards except that public entities shall provide accessible
mobility features complying with section 807.2 of the 2010 Standards for a minimum of
3%, but no fewer than one, of the total number of cells in a facility. Cells with mobility
features shall be provided in each classification level.
(2)Alterations to detention and correctional facilities. Alterations to jails, prisons, and
other detention and correctional facilities shall comply with the 2010 Standards except
that public entities shall provide accessible mobility features complying with section
807.2 of the 2010 Standards for a minimum of 3%, but no fewer than one, of the total
number of cells being altered until at least 3%, but no fewer than one, of the total
number of cells in a facility shall provide mobility features complying with section 807.2.
Altered cells with mobility features shall be provided in each classification level.
However, when alterations are made to specific cells, detention and correctional facility
operators may satisfy their obligation to provide the required number of cells with
mobility features by providing the required mobility features in substitute cells (cells
other than those where alterations are originally planned), provided that each
substitute cell -
(i) Is located within the same prison site;
(ii) Is integrated with other cells to the maximum extent feasible;
(iii) Has, at a minimum, equal physical access as the altered cells to areas used by
inmates or detainees for visitation, dining, recreation, educational programs,
9
medical services, work programs, religious services, and participation in other
programs that the facility offers to inmates or detainees; and
(iv) If it is technically infeasible to locate a substitute cell within the same prison
site, a substitute cell must be provided at another prison site within the
corrections system.
(3) With respect to medical and long-term care facilities in jails, prisons, and other
detention and correctional facilities, public entities shall apply the 2010 Standards
technical and scoping requirements for those facilities irrespective of whether those
facilities are licensed.
10
Public Right-of-Way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
CC
"/A
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~^ ti
Y-
Appendix A2
WSDOT Local Agency Guidelines Chapter 29
Including Appendix 29.11 Checklist
WSDOT ADA Notice to Local Governments (September 2024)
December 2024
Prepared by
IM,jo-to
Transportation Solutions
INNOVATIVE I PRACTICAL I EQUITABLE
Chapter 29 Section 504 and the Americans with
Disabilities Act
29.1 General Discussion
This chapter summarizes the regulations and implementing requirements local agencies
shall follow regarding services, programs, and activities in or that affect the public right
of way.
Section 504 of the Rehabilitation Act of 1973 (Section 504)states that no person with
a disability shall be excluded from participation in, denied the benefits of, or be subjected
to discrimination under any program or activity that receives Federal funding.This
includes both transportation and non-transportation funding.Transportation funding
includes funding from the United States Department of Transportation (USDOT) or the
operating administrations under it (Federal Highway Administration, Federal Transit
Administration, Federal Railroad Administration, Federal Aviation Administration, Research
and Special Programs Administration, National Highway Traffic Safety Administration, or
the U.S. Coast Guard).
Section 504 extends to the entire operations of a recipient or subrecipient, regardless of
the specific funding source of a particular operation. Section 504 Regulations (49 CFR
Part 27.5) define a recipient as any public entity that receives Federal financial assistance
from the USDOT or its operating administrations either directly or through another
recipient.An example of a recipient is WSDOT an example of a subrecipient is a local
agency receiving USDOT funds through WSDOT, for projects/programs/activities
administered by the local agency.
All public entities shall follow the Americans with Disabilities Act of 1990 (ADA),
regardless of funding sources.The ADA is mirrored after Section 504 but extends the
reach of Federal accessibility laws to include those agencies that are not recipients or
subrecipients of Federal funding.Title II (28 CFR Part 35) of the ADA specifically pertains
to state and local governments.
The respective Federal funding agency(FHWA) and WSDOT will ensure that local
agencies comply with Section 504 and the ADA. For more information about Section 504
and the ADA, please see WSDOT Equal Opportunity ADA website: www.wsdot.wa.gov/
EqualOpportunity/ADA.htm
Local agency public works staff should also refer to Chapter 42 of the Local Agency
Guidelines (LAG) for technical information specific to public right-of-way facilities.
WSDOT Local Agency Guidelines M 36-63.42 Page 29-1
September 2023
29.2 Assurances
Each local agency that receives Federal funding from the USDOT or its operating
administrations (such as FHWA) shall submit a written assurance that all of its services,
programs, and activities will be conducted in compliance with Section 504 and the ADA.
The assurance shall be signed by the Agency Executive, and submitted to each agency
(such as WSDOT) administering funds for the USDOT or an operating administration.
Federal aid projects administered through WSDOT require a Local Agency Agreement
between the local agency and WSDOT. That agreement may serve as the local agency's
assurance of compliance with Section 504 and the ADA as long as it is signed by the
Agency Executive and states the following:
In accordance with Section 504 and the ADA, the Agency shall not discriminate on the
basis of disability in any of its programs,services, or activities.
29.3 Administrative Requirements
The following list and Appendix 29.11 summarize some of the key requirements of
Section 504 and the ADA. Note that when a requirement cites a number of employees,
that number is the number of paid permanent, temporary, and contract employees
regardless of whether the employees are full or part time.
• Each agency, regardless of the number of employees and funding sources, shall ensure
that its services, programs, and activities are accessible to persons with disabilities.
Some things this includes are:
- Transportation and community evacuation elements of emergency management
programs/plans
- Communications. Communications with persons with disabilities shall be as
effective as communications with other persons.This applies to all forms of
communications, including information posted on an agency's website (ref. Section
508 of the Rehabilitation Act and the ADA), emergency services communications,
pedestrian signal systems, etc.
- Maintenance of programs and facilities.This includes maintaining accessibility of
pedestrian facilities that may be impacted by overgrown vegetation, snow/ice,
severe heaving/cracking of surfaces, construction work zones, etc. Pedestrian
signals/pushbuttons must also be accessible and maintained in working order.
- New construction and altered facilities.
• Each agency regardless of the number of employees shall designate at least one
person as its ADA/504 Coordinator.The individual designated as the ADA/504
Coordinator is responsible for coordinating ADA/Section 504 compliance throughout
the agency.The agency shall provide the name, office address, and telephone number
of the ADA/504 Coordinator both internally and externally.This information is
required to be posted in areas likely to be viewed by employees and the general public
(such as the agency's Web page, etc.).
• Each agency regardless of the number of employees shall adopt and publish
grievance/complaint procedures.These procedures shall be posted internally
and externally and be made available in alternative formats that address the needs of
persons with mobility,visual, and hearing disabilities.This information is required to
be posted in areas likely to be viewed by employees and the general public (such as
the agency's Web page).
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September 2023
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• Each agency, regardless of the number of employees, shall provide public notice of its
ADA provisions.This notice shall contain a brief description about how the agency will
address ADA accessibility in its employment, communications, policies, and resolution
of complaints.This notice shall be placed in locations and/or facilities that are
accessible internally and externally and be available in alternative formats that address
the needs of persons with mobility,visual, and hearing disabilities. Information placed
on the agency's Web page counts as posting externally.
• Each agency, regardless of the number of employees, shall conduct a self-evaluation
of its policies, programs, services, and activities to determine whether Section 504/
ADA accessibility requirements are being met.This includes all public right-of-way
facilities. See Appendix 29.11. Each agency shall provide an opportunity for interested
parties (i.e., persons with disabilities/advocacy groups) to participate in the process.
• Each agency with 50 or more employees shall develop a transition plan (See Section
29.4)when structural modifications, identified through a self-evaluation process,
are necessary to achieve program accessibility under the ADA. While Section 504
regulations contain similar requirements, there is no employee threshold and the
regulation is not as descriptive as the ADA regulations.Therefore, each agency with
fewer than 50 employees that is a recipient or subrecipient of Federal financial
assistance shall develop a program access plan. See Section 29.4 for the requirements
of these plans.
An agency's self-evaluation and transition plan must cover all of the agency's
programs (including facilities), services, and activities.The information contained
in this chapter is intended to provide local agency transportation departments
(i.e., public works)with guidance/expectations for addressing ADA accessibility
requirements associated with public right-of-way facilities.
29.4 Transition Plan, Program Access Plan, and Accessible Pedestrian
Signal and Pushbutton Policy
Each agency shall provide an opportunity for interested parties (i.e., persons with
disabilities/advocacy groups) to participate in the process to develop a transition plan or
program access plan.
FHWA considers transition plans and program access plans to be living documents.
The applicable plan should be used in conjunction with the planning and prioritizing of
projects, and for monitoring progress on completing modifications. If the time period of
the plan is longer than one year, the plan shall identify steps that will be taken during each
year of the transition period. FHWA also recommends that the plan be updated annually
until all planned modifications have been completed.
Transition Plan
As stated in Section 29.3 of this chapter, agencies with 50 or more employees (ADA),
regardless of funding source, shall develop a transition plan when structural modifications
are necessary to achieve ADA compliance. Based on the agency's self-evaluation, at a
minimum the plan shall:
• Identify the physical obstacles in the public entity's facilities that limit the accessibility
of its programs or activities to individuals with disabilities, including those within the
public right of way.
• Describe in detail the methods that will be used to make the facilities accessible.
WSDOT Local Agency Guidelines M 36-63.42 Page 29-3
September 2023
-------- -- - ---- ----------------- ------ ----------------
• Specify the schedule for each facility and/or obstacle to be retrofitted. FHWA
recommends that an agency include the estimated cost of each modification as part
of the schedule, to assist in the budget and/or Transportation Improvement Program
(TIP) preparation.
• Identify the official responsible for implementation of the plan.This is typically the
agency's Executive, or the agency's designated ADA/504 Coordinator who has the
authority to act on behalf of the agency's Executive.
Program Access Plan
As stated in Section 29.3, agencies with fewer than 50 employees and a recipient of
Federal financial assistance are required to develop a program access plan. Similar to a
transition plan, agencies shall:
• Identify the physical obstacles in the public entity's facilities that limit the accessibility
of its programs or activities to individuals with disabilities, including those within the
public right of way.
• Describe in detail the methods/actions needed to make the facilities accessible.
• Specify a schedule (milestones) of when the agency plans to make the
necessary modifications.
Accessible Pedestrian Signal and Pushbutton (APS) Policy
Based on input from the U.S. Department of Justice (DOJ), it is FHWA's policy to require
recipients and subrecipients (of FHWA funding) to establish a "reasonable and consistent"
policy for installing accessible pedestrian signals and pushbuttons (APS) on all alteration
and new construction projects, consistent with the requirements of Title 11 of the ADA(28
CFR Part 35.151) and Section 504 regulations (49 CFR Part 27.7(c)).This policy should be
part of a transition plan, program access plan, or a stand-alone document if a transition
plan or program access plan has not yet been completed. FHWA and WSDOT will work
with local agencies to ensure that all new and altered pedestrian signal and pushbutton
installations are usable by persons with visual disabilities.
29.5 Requirements for New Construction and Alterations in the Public
Right of Way
Title 11 of the ADA requires that new and altered facilities be designed and constructed to
be readily accessible to and usable by persons with disabilities.
New Construction
New construction projects address the construction of a new roadway, interchange, or
other transportation facility where none existed before. New construction is expected
to meet the highest level of ADA accessibility unless it is structurally impracticable to
achieve full compliance. Full compliance will be considered structurally impracticable only
when, in rare circumstances, the unique characteristics of terrain prevent full compliance.
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September 2023
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Alterations
The vast majority of construction projects undertaken by local agency public works/
transportation departments are classified as alterations.An alteration is a change that
affects or could affect the usability of a facility or part of a facility.Alterations include
reconstruction, major rehabilitation, widening, resurfacing (e.g., asphalt overlays and
mill and fill), signal installation and upgrades, and projects of similar scale and effect.
Alterations to existing facilities shall meet new construction standards unless it is
technically infeasible to do so. If full ADA compliance cannot be achieved in an alteration,
the agency shall alter the facility to provide the maximum degree of accessibility possible.
The feasibility meant by this standard is physical possibility only. Neither cost nor
schedule are factors in determining whether the ADA standards can be met, nor are they
factors in determining the feasibility of complying with the standard.
An alteration project shall be planned, designed, and constructed so that the required
accessibility improvements occur at the same time as the alteration. If a project involves
resurfacing the street, connections between the sidewalk and street crossings (i.e., curb
ramps) are considered to be within the scope of the alteration project.Any accessibility
issues shall be addressed in conjunction with the resurfacing project, either prior to or
at the same time as the resurfacing project. For the requirements for curb ramps during
resurfacing projects, see USDOJ-USDOT's Joint Technical Assistance document, dated
July 8, 2013 and the Supplement to this document, dated December 1, 2015; and a
FHWA recorded webinar from FHWA, dated March 1, 2016.
Safe Harbor for Alterations
Both the Section 504 and ADA requirements contain a "safe harbor" provision. However,
there is a difference in the timeline associated with the Section 504 safe harbor provision
and the ADA safe harbor provision.
If an agency receives Federal financial assistance from USDOT - either directly or through
another USDOT recipient (such as WSDOT), the agency is subject to the 2004 ADA
Accessibility Guidelines (2004 ADAAG).
This became effective in 2006 when the USDOT adopted the 2004 ADA Accessibility
Guideline (2004 ADAAG) into its Section 504 regulations.This document is known as the
2004 ADA Standards.The 2004 Standards have a "safe harbor" provision for curb ramps.
The provision is that if a curb ramps was constructed or altered prior to November 29,
2006, and complies with either the 1991 ADA Standards for Accessible Design (1991
ADA Accessibility Guidelines) or the Uniform Federal Accessibility Standards (UFAS), it
does not need to be modified as part of a roadway resurfacing project. If this is not the
case, or if the curb ramp is in disrepair then the curb ramp and its detectable warnings
(truncated domes) must shall be brought into compliance with the 2004 Standards) at the
time of an alternation.As mentioned above in Section 29.1, if an agency receives Federal
financial assistance from USDOT - either directly or through another DOT recipient
(such as WSDOT), then the agency is subject to the 2004 ADAAG as part of the USDOT
Section 504 regulations.
For those agencies who are not a recipient or subrecipient of Federal financial assistance
from USDOT, the safe harbor provision in the 2010 ADA Standards for Accessible Design
(2010 Standards) applies. Under the 2010 Standards' safe harbor provision, if curb ramps
were built or altered (in existing facilities) prior to March 15, 2012 and if they comply with
WSDOT Local Agency Guidelines M 36-63.42 Page 29-5
September 2023
the 1991 Standards or the UFAS, they do not need to be modified as part of a resurfacing
project.
However, if an existing curb ramp does not comply with either the 1991 Standards or the
UFAS (including if the curb ramp is in a state of disrepair), then the Safe Harbor provision
does not apply and the curb ramp would need to be brought into compliance with the
2010 Standards at the time of roadway alteration.
When curb ramps or abutting sidewalks abutting ramps are altered, they shall be
reconstructed to meet the 2010 Standards. For additional curb ramp design guidance, see
LAG manual Chapter 42.
Documentation for Structural Impracticability and Maximum Extent Feasible
While ADA/Section 504 regulations do not require documentation of the application of
structural impracticability nor maximum extent feasible, both FHWA and the U.S.Access
Board recommend that these instances be documented so the agency can support its
decisions if challenged at a later date.The documentation of these instances should reveal
the standard of care that guided engineering judgments. While careful documentation will
not protect an agency against complaint, evidence of the considerations that led to the
specific project solution may be persuasive in discussions with stakeholders or in court.
As described in the Design Manual M 22-01, WSDOT has a documentation procedure
for applications of maximum extent feasible in alteration projects on state routes. If a
local agency applies maximum extent feasible to a pedestrian facility located on a state
route, it is WSDOT's expectation that the agency follow the WSDOT documentation
procedure described in the Design Manual M 22-01.The completed documentation
should be contained in local agency project files to document the agencies design efforts
in complying with the ADA/Section 504 requirements.
If a local agency finds the need to apply maximum extent feasible to a pedestrian facility
that is not located on a state route, the WSDOT documentation procedure does not
need to be followed. However, it is highly recommended that the agency develop its own
documentation protocol for such situations that is consistent with the FHWA and U.S.
Access Board recommendations.
29.6 Monitoring and Enforcement
Responsibility for monitoring and enforcement of Section 504 rests with the Federal
funding agency(such as FHWA). While USDOJ has the ultimate enforcement authority
for ADA compliance, USDOJ has delegated monitoring and enforcement responsibility to
several Federal executive agencies including the USDOT and its operating administrations
(such as FHWA).
FHWA requires WSDOT to monitor and enforce the compliance with both Section 504
and the ADA of any entity receiving disbursement of either state or Federal funding
through WSDOT. FHWA monitors WSDOT and local agency compliance through various
means such as process and program reviews, construction inspections, PS&E reviews,
and complaint investigations. If noncompliance is found, and the noncompliance is not
corrected to FHWA's satisfaction, FHWA may terminate existing Federal funding or
refuse to grant future funding.
Page 29-6 WSDOT Local Agency Guidelines M 36-63.42
September 2023
29.7 Laws
• 29 USC 794 - Section 504 of the Rehabilitation Act of 1973 (as amended by the Civil
Rights Restoration Act of 1987)
• 42 USC 12111 - Americans with Disabilities Act (Title II)
29.8 Regulations
• 28 CFR Part 35 (Title II) "Nondiscrimination on the Basis of Disability in State
and Local Government Services"
• 49 CFR Part 27 (Section 504) "Nondiscrimination on the Basis of Disability
in Programs or Activities Receiving Federal Financial Assistance"
• 49 CFR Part 37 "Transportation Services for Individuals with Disabilities (ADA)
• 49 CFR Part 38 "Americans with Disabilities Act (ADA)Accessibility Specifications for
Transportation Vehicles"
29.9 Resources
• Chapters 1510 and 1515 of the Design Manual M 22-01
• Chapter 42 of this manual
29.10 Appendices
29.11 ADA Title II and Section 504 Regulatory References
WSDOT Local Agency Guidelines M 36-63.42 Page 29-7
September 2023
Appendix 29. 11 ADA Title 11 and Section 504 Regulatory
References
Requirements Requirements
ADA Title II and for agencies for agencies
Rehabilitation Act Section 504 with less than with 50 or more
Regulatory References 50 employees employees
Programs, Services, and Activities: Ensure that programs, services,
and activities are accessible to persons with disabilities. ✓ ✓
(28 CFR Part 35.150(a) and (c))
ADA/504 Coordinator: Designate at least one responsible employee
(ADA/504 Coordinator) and make the name and contact information ✓ ✓
available internally and externally.
(28 CFR Part 35.107(a) and 49 CFR Part 27.13(a))
Complaint/Grievance Procedures:Adopt and publish complaint/
grievance procedures. ✓ ✓
(28 CFR Part 35.107(b) and 49 CFR Part 27.13(b))
Notice of ADA Provisions: Provide a public notice of how the agency
will address ADA accessibility in its employment, communications, ✓ ✓
policies, and resolution of complaints.
(28 CFR 35.106)
Self-evaluation2: Evaluate all services, policies, and practices for
barriers that restrict/limit persons with disabilities from access to services, ✓ ✓
programs, and activities.
(28 CFR Part 35.105(a)and 49 CFR Part 27.11(c)(2)(i) and (v))
Self-evaluation2: Maintain the completed self-evaluation on file and
make it available for public inspection for at least three years following its ✓ ✓
completion.
(28 CFR Part 35.105(c) and 49 CFR Part 27.11(c)(3)(ii):
Transition Plan2/Program Access Plan: Develop a transition plan ✓
or program access plan that outlines the structural modifications that ✓ transition plan
must be made to those services, programs, and activities that are not program access (post it on
accessible. plan the agency's
(28 CFR Part 35.150(d) and 49 CFR Part 27.11(c)(2)(ii)) website)
Accessible Pedestrian Signal and Pushbutton (APS) Policy2:
Develop a "reasonable and consistent" policy for installing accessible
pedestrian signals and pushbuttons when a transition plan has not yet ✓ ✓
been completed.
(28 CFR Part 35.130 and 35.160a(1)and 49 CFR Part 27.7(c))
Notes:
'Employees include paid permanent, temporary, and contract employees regardless of whether the employees
are full or part time.
2Complete self-evaluations, and develop transition plans, program access plan and APS policies
by engaging persons with disabilities and/or their advocates (28 CFR Parts 35.105 and 35.150 and
49 CFR Part 27.11(c)(2)).
Page 29-8 WSDOT Local Agency Guidelines M 36-63.42
September 2023
Adm
MW
Washington State Transportation Building
Department of Transportation 3O.Maple Park Avenue S.E.
P.O.Box 47300
Olympia,WA 98504-7300
360-705-7000
TTY: 1-800-833-6388
www.wsdot.wa.gov
September 5, 2024
Dear Local Agency Partners,
Purpose
The Washington State Department of Transportation (WSDOT)remains committed to providing
equitable access to Washington's multimodal transportation system,which includes users with
disabilities. The purpose of this letter is to notify all local agencies with more than fifty full-
time employees and who receive federal funds from WSDOT must provide copies of their
transition plan by January 1,2025.
Background
As a State Transportation Agency (STA), WSDOT has the responsibility to monitor sub-
recipients of federal assistance to ensure their compliance with Title II of the ADA and Sec. 504.
This includes STA-funded(both federal and state dollars)projects and programs that the sub-
recipients implement.
Under the ADA and its implementing regulations 128 CFR § 35.130(b)(1)(v))}, the state cannot
aid or perpetuate discrimination against an individual with a disability by providing significant
assistance to an entity that discriminates in providing any aid,benefit, or service to beneficiaries.
Similarly, Section 504 of the Rehabilitation Act(Section 504) and its implementing regulations
(49 CFR § 27.7 (b)(v))provides that a recipient of Federal Highway Administration (FHWA)
funds (e.g. the State)cannot provide financial or other assistance to an agency, organization, or
person that discriminates based on disability in providing any aid,benefit, or service. As such,
WSDOT is lawfully forbidden from providing funds to a local agency that does not comply with
ADA and Section 504.
To remain in compliance with ADA and Section 504,WSDOT will be requiring all local
agencies with more than fifty fulltime employees and are receiving FHWA funds to provide
documentation demonstrating they have started, or completed, an ADA transition plan by
January 1,2025.
Who is covered?
If WSDOT provides FHWA funds to a local government agency or other entity with more than
fifty fulltime employees, all the operations of the agency, department, or organization to which
the funds are distributed are covered. Enhancement grants, safe routes to school funds, earmarks,
as well as local highway user revenue distributions are some examples of qualifying funds and
therefore recipients must demonstrate compliance in all programs.
Local Agency Partners
September 5, 2024
Page 2 of 4
What is an ADA transition plan?
An ADA transition plan identifies barriers to ADA compliance and provides actions that a sub-
recipient will take over the next several years to remove barriers within the public right of way
and all sub-recipient owned facilities identified during the sub-recipient's continued self-
evaluation efforts. Sub-recipients demonstrate their commitment to achieving substantial ADA
compliance through a comprehensive approach outlined in their plans. This approach includes
strategies for public engagement and involvement, details on agency wide ADA roles and
responsibilities, and a plan to identify, prioritize, and address ADA features in public facilities
and public right-of-way.
What documentation is sufficient to demonstrate that a plan has been started or
completed?
Sufficient documentation if an ADA Transition Plan has been completed
If a plan transition plan has been completed, local governments must provide a copy of the plan
to WSDOT's Office of Equity and Civil Rights. Copies of the plan can be emailed directly to
wsdotadaa,wsdot.wa. og_v.
Sufficient documentation if an ADA Transition Plan has not been completed
If a plan has not been completed, local governments must email documentation demonstrating
that the drafting of a plan is in progress. Examples of sufficient documentation include, but are
not limited to, the following:
• A copy of a transition plan draft;
0 A written commitment from the local government to complete a plan by a certain date;
• A schedule for when a plan will be completed;
• Any written documents that demonstrate actions are being taken to complete a plan;
• Copy of an active ADA grievance process;
• Any inventories or assessments of existing barriers or three or more ADA-related features
(best practice minimum -curb ramps, pedestrian signals and sidewalks);
• Copy of an active ADA Policy Statement.
At a minimum,the documentation must show an assurance that the local government is
committed to completing a transition plan within a reasonable amount of time. Questions
regarding sufficient documentation can be emailed to wsdotada@,wsdot.wa gov.
Local Agency Partners
September 5, 2024
Page 3 of 4
What is required of Local governments and other entities' ADA Transition Plans?
All Sub-recipient ADA Transition Plans must include the following elements:
• Identity the local agency's ADA Coordinator by name and include contact information;
• The Sub-recipient's current ADA policy;
• A grievance procedure for ADA complaints;
• The ADA self-evaluation results (for programs and facilities);
• The design standards for all facilities (e.g.,buildings and roadway assets); and
• A prioritization schedule for remediating assets and programs that are not ADA
compliant, including the subrecipient's commitment to complete the schedule by:
identifying either(if not both) of the following:
o The completion date for each item on the schedule; or
o A budget to be applied to the items on the prioritization schedule together with
cost estimates for their remediation.
• A summary of all the public involvement opportunities involved in the development of
the plan;
• A schedule of how the plan will be updated(every five years, for example.)
How will WSDOT evaluate Sub-recipient plans?
WSDOT requests that local governments provide documentation they have either completed or
started an ADA transition plan by January 1,2025.
Upon receiving completed plans, WSDOT will review and provide feedback on whether the
plans meet the federal requirements. A copy of the rubric WSDOT will be using to evaluate
ADA transition plans is attached to this letter. If an ADA transition plan is not complete,
WSDOT will work with the local agency to determine any corrective action and a timeline to
complete it.
Local Agency Partners
September 5, 2024
Page 4 of 4
To assist local governments with meeting the January 1,2025 deadline, WSDOT's ADA team
is available for questions about, and technical assistance with developing ADA transition plans.
To request technical assistance,you can contact WSDOT's ADA Compliance Team through
email at wsdotada a�wsdot.wa.gov or by calling 1-855-362-4232.
Sincerely,
9 A
Earl Key Esq. LL.M, M.S.
Senior Director of Transportation Equity
Enclosure: ADA Transition Plan Evaluation Rubric
cc: Jackie Bayne, Deputy Director, Office of Equity & Civil Rights
Shawn Murinko, Assistant Director of ADA Compliance&External Workforce
Autumn Young, Civil Rights Program Manager of Federal Highway Administration
Development
Jay Drye, Director of Local Programs
Reema Griffith, Executive Director of the Washington State Transportation Commission
Americans with Disabilities Act(ADA) Information
WSDOT is committed to providing equal access to its facilities,programs and services for
persons with disabilities. The material contained in this document can be made available in
an alternate format by emailing the WSDOT Diversity/ADA Affairs team at
wsdotada@wsdot.wa.gov or by calling toll free: 855-362-4ADA (4232). Persons who are
deaf or hard of hearing may make a request by calling the Washington State Relay at 711.
Exhibit 1
ADA Transition Plan Evaluation Rubric
Plans will be scored across seven categories as acceptable, unacceptable, or exceeding minimum
criteria.
Category One-Official Res onsible for Implementation of ADA Transition Plan
Exceeds Minimum Criteria Acceptable Unacceptable
Primary manager, name, title Primary manager,name, title Not included in document or
and role included along with and role included in plan or name or title listed,but not
delegation by agency website; may also include both; lacks identification of
directory or equivalent; all or delegation by agency role
other key ADA contacts directory or equivalent
within the organization
named, including titles and
roles
Category Two-Inventory of Barriers
Exceeds Minimum Criteria Acceptable Unacceptable
Includes results of inventory, Includes results of inventory Lacks sufficient inventory to
assessments and summary of and assessments for at least evaluate barriers and/or lacks
inventory methodology for two ADA-related features plan to build such data for
three or more ADA-related (best practice minimum- self-evaluation
features (best practice sidewalks and curb ramps or
minimum-curb ramps, curb ramps and pedestrian
pedestrian signals and signals); may include
sidewalks); or meets criteria summary of inventory
for"Acceptable," but methodology
includes plan and/or schedule
for expanding evaluation to
other features or assets
Category Three-Modification Schedule
Exceeds Minimum Criteria Acceptable Unacceptable
Plan shows a strong Plan shows some Lacks sufficient commitment
commitment toward commitment toward to eliminate barriers and/or
upgrading ADA elements upgrading ADA elements lacks plan to build a schedule
identified in the inventory of identified in the inventory of and committed resources
barriers in the short term barriers in the short term
(planned capital improvement (planned capital improvement
projects) and a strong projects) and a recognition of
commitment over time priority of curb ramps at
toward prioritizing curb walkways serving entities
ramps at walkways serving covered by the ADA. 28
entities covered by the ADA. CFR 35.150(d)(2). May
28 CFR 35.150(d)(2). This include some planning for
would also include elimination of other barriers
prioritization information, over time. 28 CFR
planning, and investments 35.150(d)(3). Resources to
directed at eliminating other eliminate identified ADA
identified barriers over time. deficiencies may or may not
28 CFR 35.150(d)(3). be identified, but may not be
Resources dedicated to dedicated.
eliminate identified ADA
deficiencies.
Category Four-Accessibili Methods
Exceeds Minimum Criteria Acceptable Unacceptable
Describe in detail the Describe most of the Incomplete description of the
Methods that will be used to Methods that will be used to Methods that will be used to
make the facilities accessible. make the facilities accessible. make the facilities accessible.
28 CFR 35.150(d)(3)(ii); 28 CFR 35.150(d)(3)(ii); 28 CFR 35.150(d)(3)(ii);
standards that will be applied primary standards that will be and/or standards that will be
and any applied clearly identified(i.e., applied not clearly identified
modifications/refinements 2010 ADAAG,2011 and/or defined(i.e., 2010
clearly defined(i.e., 2010 PROWAG) ADAAG, 2011 PROWAG)
ADAAG, 2011 PROWAG
Category Five- Public Involvement
Exceeds Minimum Criteria Acceptable Unacceptable
Description of process to Description of process to Incomplete or unclear process
allow public to readily access allow public to readily access to allow public to readily
and submit comments for and submit comments for access and submit comments
both self-evaluation and both self-evaluation and for both self-evaluation and
transition plan. 28 CFR transition plan. 28 CFR transition plan.
35.150(d)(1); 28 CFR 35.150(d)(1); 28 CFR
35.105(b). Best practices: a) 35.105(b).
detailed list of individuals
consulted posted
conspicuously on website,
does not have to be in actual
TP,but must be documented
and available;b)have both
electronic and hard copy
notice. 28 CFR 35.105 c
Category Six-ADA Policy Statement
Exceeds Minimum Criteria Acceptable Unacceptable
Not required of local N/A(Not required of local N/A(Not required of local
agencies,but best practice if agencies) agencies)
mentioned and link provided
to policy posted
conspicuously on website
Category Seven -Complain e uest/Grievance Process
Exceeds Minimum Criteria Acceptable Unacceptable
Description of process and Basic information included to Insufficient information
detailed information included help an individual know how included to help individuals
to help an individual know to submit a request for know how to submit a request
how to submit a request for accommodation or file a for accommodation or file a
accommodation or file a formal complaint; link to formal complaint
formal complaint; more than form or other method
one option provided included
(including assisted)to allow
individuals to submit issue
Public Right-of-way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
ON
C.
ti
Appendix B1
Public Notice of ADA Provisions
December 2024
Prepared by
Transportation Solutions
INNOVATIVE I PRACTICAL I Eq UITABI I
~= � Jefferson County 0N
Y ; Public Notice Under the Americans with
Disabilities Act
w'.,r+r'u
Y
In accordance with the requirements of title II of the Americans with Disabilities Act of 1990 ("ADA"),
Jefferson County will not discriminate against qualified individuals with disabilities on the basis of
disability in its services, programs, or activities.
Employment:Jefferson County does not discriminate on the basis of disability in its hiring or
employment practices and complies with all regulations promulgated by the U.S. Equal Employment
Opportunity Commission under title I of the ADA.
Effective Communication:Jefferson County will generally, upon request, provide appropriate aids and
services leading to effective communication for qualified persons with disabilities so they can participate
equally in Jefferson County programs, services, and activities, including qualified sign language
interpreters, documents in Braille, and other ways of making information and communications
accessible to people who have speech, hearing, or vision impairments.
Modifications to Policies and Procedures:Jefferson County will make all reasonable modifications to
policies and programs to ensure that people with disabilities have an equal opportunity to enjoy all of its
programs, services, and activities. For example, individuals with service animals are welcomed in
Jefferson County offices, even where pets are generally prohibited.
Anyone who requires an auxiliary aid or service for effective communication, or a modification of
policies or procedures to participate in a program, service, or activity of Jefferson County should contact
the office of Shawn Frederick, ADA/504 Coordinator, by email at SFrederick@co.iefferson.wa.us or by
phone at 360-385-9362 (for TTY, dial 7-1-1), as soon as possible but no later than 48 hours before the
scheduled event.
The ADA does not require Jefferson County to take any action that would fundamentally alter the nature
of its programs or services, or impose an undue financial or administrative burden.
Complaints that a program, service, or activity of Jefferson County is not accessible to persons with
disabilities should be directed to Shawn Frederick,ADA/504 Coordinator, by email at
SFrederick@ co.0efferson.wa.us or by phone at 360-385-9362 (for TTY, dial 7-1-1).
Jefferson County will not place a surcharge on a particular individual with a disability or any group of
individuals with disabilities to cover the cost of providing auxiliary aids/services or reasonable
modifications of policy, such as retrieving items from locations that are open to the public but are not
accessible to persons who use wheelchairs.
Public Right-of-way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
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Appendix 62
ADA Complaint/Grievance Procedure
November 2024
Prepared by
Transportation Solutions
INNOVATIVE I Dp ACTIC AL I EQUITABLE
ADA Complaint Procedure (Resolution 18-06)
This procedure may be used by anyone who wishes to file a complaint alleging discrimination on the
basis of disability in the provision of services, activities and programs of Jefferson County.
Step 1 -The Written Complaint
A complaint should be in writing, contain the name and address, phone number and e-mail (if
available) of the person filing it, and the location, date and a description of the problem or the
action alleged to be prohibited by the ADA and/or Section 504 (45 CFR Part 84). Alternative means
of filing complaints will be made available for persons with disabilities upon request.
A complaint should be filed as soon as possible in the office of the ADA Coordinator, but no later
than 60 working days after the person filing the complaint becomes aware of the problem or action
alleged to be prohibited by either or both regulations.The ADA Coordinator shall confirm the date
of receipt of the complaint to the complainant in writing or via an alternative means if requested.
Step 2 - Meeting with Complainant and Investigation by the ADA Coordinator
Within 30 working days of the receipt of a written complaint the ADA Coordinator, or their designee,
will meet with the complainant to discuss the complaint and shall conduct such investigation of the
complaint as may be appropriate to determine its validity. These rules contemplate informal but
thorough investigations, affording all interested persons and their representatives, if any, an
opportunity to submit evidence relevant to the complaint.
Step 3 -Written Decision
The ADA Coordinator, or that person's designee, shall issue a written decision determining the
validity of the complaint and/or the position of Jefferson County no later than 45 working days
after receipt. Alternative means of providing a written decision will be made available for persons
with disabilities upon request.
ADA Complaint Procedure(Resolution 18-06) 2017122_AOAComplointProcedure CF Page 1 of 2
Step 4-Appeal
If the response by the ADA Coordinator does not resolve the issue to the satisfaction of the
complainant,the complainant may appeal to the County Administrator.The County Administrator shall
confirm in writing to the complainant the date of receipt of the appeal or confirm via an
alternative means if requested. Said appeal shall be in writing and received by the County
Administrator within fifteen (15)working days from the date of the written response.
Alternative means of filing an appeal will be made available for persons with disabilities upon
request. After receiving the appeal,the County Administrator will review it and respond in
writing or a format accessible to the complainant as a final resolution of the complaint within
twenty(20) working days.The appeal to the County Administrator shall be the final administrative
appeal process provided by the County.
ADA Complaint Procedure(Resolution 18-06) 2017122_ADA ComplaintProcedure LF Page 2 of 2
Public Right-of-Way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
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Appendix B3
Accessible Pedestrian Signal and Pushbutton (APS) Policy
December 2024
Prepared by
Transportation Solutions
Opto
INNOVATIVE j PRACTICAL I EQUITABLE
JEFFERSON COUNTY PUBLIC WORKS
'i. 623 Sheridan Street
Port Townsend, WA, 98638
Phone (360) 385-9160
Monte Reinders, P.E., Public Works Director/County Engineer
Policy Regarding Installation of Accessible Pedestrian Signals(APS)and Pushbuttons
Any future installation or alteration'of vehicular traffic signals, pedestrian traffic signals, or pedestrian
actuated warning beacons will include APS consistent with the most recently adopted versions of the
PROWAG,WSDOT Design Manual, and MUTCD.
Any future installation of vehicular traffic signals, pedestrian traffic signals, or pedestrian actuated warning
beacons will be based upon a site-specific engineering analysis consistent with the most recently adopted
versions of the PROWAG,WSDOT Design Manual, and MUTCD.
'As of November 2024,there are currently no vehicular traffic signals, pedestrian traffic signals, or
pedestrian actuated warning beacons under Jefferson County jurisdiction.
2024 Jefferson County APS Policy Page 1
Public Right-of-Way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
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Appendix C1
GIS Curb Ramp ADA Inventory and Prioritization
December 2024
Prepared by
Transportation Solutions
Curb Ramp ADA Inventory
TSI_ID TSI_ADA_Compliance_2024 TSI_Grade TSI_Rating TSI_Notes TSI_Ramp_Photo_ID
CR_0001 Y A Fair or Better <Nutt> CR_0001.jpg
CR_0002 Y A Fair or Better <Nutt> CR_0002.1pg
CR_0003 Y A Fair or Better <Null> CR_0003.jpg
CR_0004 Y A Fair or Better <Nutt> CR_0004.jpg
CR_0005 IY A Fair or Better <Nutt> CR_0005.jpg
CR70006 Y A Fair or Better Vegetation CR_0006.jpg
CR_0007 Y A Fair or Better <Nutt> CR_0007.jpg
CR_0008 Y A Fair or Better <Nutt> CR_0008.jpg
CR_0009 N A Fair or Better Landing cross slope exceeds 2% CR_0009.jpg
CR_0010 Y A Fair or Better <Nutt> CR_0010.jpg
CR_0011 Y A Fair or Better <Null> CR_0011.jpg
CR_0012 N A Fair or Better Landing slopes exceed 2% CR_0012.jpg
CR_0013 N A Fair or Better Ramp cross slope exceeds 2% <Nutt>
CR_0014 N C Very Poor Vegetation,panel upheaval CR_0014.jpg
CR_0015 N C Very Poor No landing,old DWS CR_0015.jpg
CR_0016 N C Very Poor No landing,running slope exceeds 8.3% CR_0016.jpg
CR_0017 N C Very Poor No landing CR_0017.jpg
CR_0018 N C Very Poor No landing CR_0018.jpg
CR_0019 N C Very Poor No landing CR_0019.jpg
CR_0020 N B Poor No landing CR_0020.jpg
CR_0021 Other Other Other Future Paved apron from bollards should have DWS <Nutt>
CR_0022 N Other Other No DWS <Nutt>
CR_0023 N B Poor <Nutt> CR_0023.jpg
CR_0024 N B Poor Vegetation CR_0024.jpg
CR_0025 N B Poor Unevean transition to asphalt CR_0025.jpg
CR_0026 N B Poor No landing CR_0026.jpg
CR_0027 N A Fair or Better Vegetation Landing,not level CR_0027.1pg
CR_0028 N A Fair or Better Ramp does not extend 15 feet back CR_0028.jpg
CR_0029 N A Fair or Better 2.3%cross slope on ramps. CR_0029.jpg
CR_0030 Y A Fair or Better <Nutt> <Null>
CR_0031 Y A Fair or Better Vegetation CR_0031.jpg
CR_0032 N A Fair or Better Ramp does not extend 15 feet back CR_0032.jpg
CR_0033 N A Fair or Better 2.7%cross slope CR_0033.jpg
CR_0034 IN A Fair or Better Landing 2.7%slope. CR_0034.jpg
CR_0035 IN A Fair or Better Ramp does not extend 15 feet CR_0035.jpg
December 2024 Page 1 of 4
Curb Ramp ADA Inventory
TSI_ID TSI_ADA_Compliance_2024 TSI_Grade TSI_Rating TSI_Notes TSI_Ramp_Photo_ID
CR_0036 Y A Fair or Better Vegetation CR_0036.jpg
CR_0037 Y A Fair or Better Vegetation CR_0037.jpg
CR_0038 N A Fair or Better Landing slope 4.3%. CR_0038.jpg
CR_0039 N A Fair or Better 10.4 running slope from transit eliding area. CR_0039.jpg
CR_0040 Y A Fair or Better Vegetation CR_0040.jpg
CR_0041 Y A Fair or Better Vegetation CR_0041.jpg
CR_0042 N A Fair or Better 13%ramp running slope CR_0042.jpg
CR_0043 N A Fair or Better Landing running slope 3.2% CR_0043.jpg
CR 0044 Y A Fair or Better <Null> <Nutt>
CR 0045 Y A Fair or Better <Null> <Nutt>
CR_0046 N A Fair or Better Ramp does not go back 15 feet CR_0046.jpg
CR_0047 N A Fair or Better Ramp does not go back 15 feet CR_0047.jpg
CR_0048 N D Missing No ramp from landing to roadway. CR_0048.jpg
CR_0049 IN Other Other End of Pedestrian Access Route CR_0049.jpg
CR 0050 N Other Other End of Pedestrian Access Route <Nutt>
CR 0051 N Other Other End of Pedestrian Access Route <Nutt>
CR_0052 N Other Other End of Pedestrian Access Route CR_0052.jpg
CR 0053 N Other Other End of Pedestrian Access Route <Null>
CR 0054 N Other Other End of Pedestrian Access Route <Nutt>
CR 0055 N Other Other End of Pedestrian Access Route <Nutt>
CR_0056 Y A Fair or Better <Nutt> CR_0056.jpg
CR 0057 N Other Other End of Pedestrian Access Route <Nutl>
CR 0058 N Other Other End of Pedestrian Access Route <Nutt>
CR_0059 Other Other Other Future Paved apron from bollards should have DWS <Nutt>
CR_0060 Y A Fair or Better <Nutt> CR_0060.jpg
CR_0061 Y A Fair or Better Vegeatation CR_0061.jpg
CR 0062 IN Other Other End of Pedestrian Access Route <Nutt>
CR_0063 N A Fair or Better DWS serves diagonal crossing CR_0063.jpg
CR_0064 N B Poor End of Pedestrian Access Route CR_0064.jpg
CR_0065 N B Poor <Null> CR_0065.jpg
CR_0066 N B Poor <Null> CR_0066.jpg
CR 0067 N B Poor <Nutt> <Null>
CR 0068 N B Poor <Nutl> <Nutt>
CR_0069 N C Very Poor <Nutt> CR_0069.jpg
CR_0070 N C Ivery Poor I Deteriorated surface CR_0070.jpg
December 2024 Page 2 of 4
Curb Ramp ADA Inventory
TSI_ID TSI_ADA_Compliance_2024 TSI_Grade TSI_Rating TSI_Notes TSI_Ramp_Photo_ID
CR_0071 N B Poor <Null> CR_0071.jpg
CR_0072 N B Poor <Null> CR_0072.jpg
10 feet wide.Vegetation management to get 48 inch Pedestrian
Access Route clearance(currently 36 inch unobstructed route).
CR_0073 IY A Fair or Better Shared Use Trail. CR_0073.jpg
CR 0074 N Other Other End of Pedestrian Access Route <Null>
CR_0075 N B Poor <Null> CR_0075.jpg
CR_0076 N B Poor Landing is not within 2%Max CR_0076.jpg
CR_0077 N B Poor Vegetation.Landing is not within 2% CR_0077.jpg
CR_0078 N B Poor Vegetation.Landing is not within 2% CR_0078.jpg
CR_0079 N Other Other End of Pedestrian Access Route CR_0079.jpg
CR_0080 N Other Other End of Pedestrian Access Route CR_0080.jpg
CR_0081 N C Very Poor Gravel landing CR_0081.jpg
CR_0082 N C Very Poor Gravel landing CR_0082.jpg
CR 0083 N Other Other End of Pedestrian Access Route <Null>
CR_0084 N Other Other End of Pedestrian Access Route CR_0084.jpg
CR_0085 I N Other Other End of Pedestrian Access Route CR_0085.jpg
CR_0086 N Other Other End of Pedestrian Access Route CR_0086.jpg
CR_0087 N Other Other End of Pedestrian Access Route CR_0087.jpg
CR_0088 N Other Other End of Pedestrian Access Route CR_0088.jpg
CR_0089 N Other Other End of Pedestrian Access Route CR_0089.jpg
CR_0090 N Other Other End of Pedestrian Access Route CR_0090.1pg
CR_0091 N Other Other End of Pedestrian Access Route CR_0091.jpg
CR_0092 N Other Other End of Pedestrian Access Route CR_0092.jpg
CR_0093 N Other Other End of Pedestrian Access Route CR_0093.jpg
CR_0094 N Other Other End of Pedestrian Access Route CR_0094.jpg
CR_0095 N Other Other End of Pedestrian Access Route CR_0095.jpg
CR_0096 N Other Other End of Pedestrian Access Route CR_0096.jpg
CR_0097 N Other Other End of Pedestrian Access Route CR_0097.jpg
CR_0098 N Other Other End of Pedestrian Access Route CR_0098.jpg
CR 0099 N Other Other End of Pedestrian Access Route <Null>
CR 0100 N Other Other End of Pedestrian Access Route <Null>
CR 0101 N Other Other End of Pedestrian Access Route <Null>
CR 0102 N Other Other End of Pedestrian Access Route <Null>
CR 0103 N Other Other End of Pedestrian Access Route 1<NuIl>
December 2024 Page 3 of 4
Curb Ramp ADA Inventory
TSI_ID TSI_ADA_Compliance_2024 TSI_Grade TSI_Rating TSI_Notes TSI_Ramp_Photo_ID
CR_0104 N Other Other End of Pedestrian Access Route <Null>
CR_0105 N Other Other End of Pedestrian Access Route <Null>
CR_0106 N Other Other End of Pedestrian Access Route <Null>
CR_0107 N Other Other End of Pedestrian Access Route <Null>
CR 0108 N Other Other End of Pedestrian Access Route <Null>
CR_0109 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0110 N B Poor Paved trail section from bollards should have DWS CR_0110.jpg
CR_0111 N B Poor Paved trail section from bollards should have DWS CR_0111.jpg
CR_0112 N C Very Poor Paved trail section from bollards should have DWS <Null>
CR_0113 N C Very Poor Paved trail section from bollards should have DWS <Null>
CR_0114 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0115 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0116 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0117 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0118 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0119 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0120 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0121 Other Other Other Future Paved apron from bollards should have DWS <Null>
CR_0122 Other 10ther Other Future Paved apron from bollards should have DWS <Null>
December 2024 Page 4 of 4
Public Right-of-way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
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Appendix C2
GIS Sidewalk and Driveway ADA Inventory and Prioritization
December 2024
Prepared by
OptTransportation Solutions
,�
INNOVATIVE I PRACTICAL I EQUITABLE
Sidewalk ADA Inventory
SW-ID TSI_ADA_Compliance TSI_Grade TSI_Condition TSI_Sidewalk_Notes SW-Photo-ID Width Shape-Length
SW_0001 Y A Fair or Better Future project SW_0001.jpg 5 91.547283
SW_0002 Y A Fair or Better Shared Use Trail SW_0002.jpg 10 324.306089
SW_0003 N C Very Poor Older sidewalk SW_0003.jpg 3 67.850051
SW_0004 N C Very Poor Older sidewalk SW_0004.jpg 3 164.014378
SW70005 N C Very Poor Older sidewalk SW_0005.jpg 3 125.186546
SW_0006 N C Very Poor Older sidewalk SW_0006.jpg 3 11.227511
SW_0007 N C Very Poor Cross slopes at driveways exceed 10% SW_0007.jpg 4 384.302584
SW_0008 N C Very Poor Cross slopes at driveways exceed 10% SW_0008.jpg 4 340.595191
SW_0009 N C Very Poor Cross slopes at driveways exceed 10% SW_0009.jpg 41 139.163794
SW_0010 N A Fair or Better Cross slopes at driveways exceed 2% SW_0010.jpg 4 452.393449
SW_0011 N A Fair or Better Cross slopes at driveways exceed 2% SW_0011.jpg 4 816.430455
SW_0012 N B Poor Older sidewalk SW_0012,jpg 4 289.513247
SW_0013 N A Fair or Better Cross slopes at driveways exceed 2% SW_0013.jpg 4 1110.499641
SW_0014 N A Fair or Better Cross slopes at driveways exceed 2% SW_0014.jpg 4 354.864954
SW70015 N C Very Poor Cross slopes at driveways exceed 10% SW_0015.jpg 4 263.786805
SW_0016 N C Very Poor Cross slopes at driveways exceed 10% SW_0016.jpg 4 311.692196
SW_0017 N C Very Poor Cross slopes at curb ramps exceed 10% SW_0017.jpg 4 92.026975
SW_0018 Y A Fair or Better Recent construction SW_0018.jpg 61 779.004756
SW_0019 Y A Fair or Better Recent construction SW_0019.jpg 6 1065.71821
SW_0020 N A Fair or Better Cross slopes occasionally exceed 2% No photo 5 73.612637
SW_0021 N A Fair or Better Cross slopes occasionally exceed 2% No photo 6 58.012916
SW_0022 N A Fair or Better Cross slopes occasionally exceed 2% No photo 5 36.277666
SW_0023 N A Fair or Better Cross slopes occasionally exceed 2% SW_0023.jpg 6 232.29323
SW_0024 N A Fair or Better Cross slopes occasionally exceed 2% No photo 51 49.688332
SW_0025 N A Fair or Better Cross slopes occasionally exceed 2% No photo 6 139.947368
SW_0026 N A Fair or Better Cross slopes occasionally exceed 2% No photo 6 47.488458
SW_0027 N A Fair or Better Cross slopes occasionally exceed 2% No photo 6 77.345324
sW_0028 N A Fair or Better Cross slopes occasionally exceed 2% No photo 6 71.59473
SW_0029 Y A Fair or Better Cross slopes occasionally exceed 2% SW_0029.jpg 5 84.691975
SW_0030 N B Poor Older sidewalk No photo 3 575.205855
SW_0031 N B Poor Older sidewalk SW_0031.jpg 3 1033.583126
SW_0032 N B Poor Older sidewalk No photo 3 503.208045
SW_0033 N B Poor Older sidewalk No photo 31 310.228669
SW_0034 N IB Poor Older sidewalk No photo 31 1742.771299
SW_0035 IN IB Poor Older sidewalk No photo 1 31 472.471774
December 2024 Page 1 of 2
Sidewalk ADA Inventory
SW ID TSI_ADA_Compliance TSI_Grade TSI_Condition TSI_Sidewalk_Notes SW-Photo-ID Width Shape-Length
SW_0036 N B Poor Older sidewalk No photo 3 774.599741
SW_0037 N B Poor Older sidewalk No photo 3 887.029795
SW_0038 N B Poor Older sidewalk No photo 3 1134.513249
SW_0039 N B Poor Older sidewalk No photo 3 754.6301
SW_0040 N B Poor Older sidewalk No photo 3 509.479401
SW_0041 N B Poor Cross slopes at driveways exceed 2% SW_0041.jpg 4 1147.371115
December 2024 Page 2 of 2
TSI_Driveway_ID SW_ADA_Compllance Grade Condition Notes TSI_Drlveway_Photo_ID Width Cross-Slope
DR_0001 N A Fair orBetter Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0002 N A Fair or Better Cross slopes exceed 2%at driveways DR_0002.jpg 60"or more Up to or equal to 2%
DR_0003 N A Fair or Better Cross slopes exceed 2%at driveways DR
_0003.jpg 60"or more Up to or equal to 2%
DR_0004 N A Fair or Better Cross slopes exceed 2%at driveways DR_0004.jpg 60"or more Up to or equal to 2%
DR_0005 N A Fair or Better Cross slopes exceed 2%at driveways DR_0005.jpg 60"or more Up to or equal to 2%
DR_0006 IN A Fair or Better 1 Cross slopes exceed 2%at driveways DR_0006.jpg 60"or more Up to or equal to 2%
DR_0007 N A Fair or Better Cross slopes exceed 2%at driveways DR_0007.jpg 60"or more Up to or equal to 2%
DR_0008 N A Fair orBetter Cross slopes exceed 2%at driveways DR_0008.jpg 60"or more Up to or equal to 2%
DR_0009 N A Fair or Better Cross slopes exceed 2%at driveways DR_0009.jpg 60"or more Up to or equal to 2%
DR_0010 Y A Fair or Better Recent construction DR_0010.jpg 60"or more Up to or equal to 2%
DR_0011 Y A Fair or Better Recent construction DR_0011.jpg 60"or more Up to or equal to 2%
DR_0012 Y A 1 Fair or Better Recent construction DR_0012.jpg 60"or more <Nutt>
DR_0013 Y A Fair or Better Recent construction DR_0013.jpg 60"or more <Nutt>
DR_0014 Y A Fair or Better Recent construction DR_0014.jpg 60"or more <Nutt>
DR_0015 Y A Fair or Better Recent construction DR_0015.jpg 60"or more <Nutt>
DR_0016 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0016.jpg <Nutt> More than 2%
DR_0017 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0017.jpg <Nutt> More than 2%
DR_0018 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0018.jpg <Nutt> More than 2%
DR_0019 N C Very Poor 1 Cross slopes exceed 10%with steep side flares DR_0019.jpg <Nutt> <Null>
DR_0020 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0020.jpg <Nutt> <Nutt>
DR_0021 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0021.1pg <Nutt> More than 2%
DR_0022 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0022.jpg <Null> More than 2%
DR_0023 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0023.jpg <Null> More than 2%
DR_0024 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0024.jpg <Null> More than 2%
DR_0025 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0025.jpg <Nutt> <Nutt>
DR 0026 N C Very Poor I Cross slopes exceed 10%with steep side flares DR 0026.jpg <Nutt> <Nutt>
DR_0027 N C Very Poor Cross slopes exceed 10%with steep side flares DR_0027.jpg 48"to>60" More than 2%
DR_0028 N A Fair or Better Some cross slopes above 2%and stamps for each driveway transition DR_0028.jpg 48"to>60" <Nutt>
DR_0029 N A Fair orBetter Some cross slopes above 2%,and stamps for each driveway transition DR_0029.jpg 48"to>60" <Null>
DR_0030 N A Fair orBetter Vegetation blocking access.Some cross slopes above 2%and stamps for each driveway transition DR_0030.jpg 48"to>60" <Null>
DR_0031 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition DR_0031.jpg 48"to>60" <Null>
DR_0032 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Null>
DR_0033 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Nutt>
DR_0034 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Nutt>
DR_0035 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Nutt>
DR_0036 N A Fair orBetter Vegetation blocking access.Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Nutt>
DR_0037 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition DR_0037.jpg <Nutt> <Null>
DR_0038 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Null> <Nutt> <Null>
DR_0039 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Null> <Nutt> <Null>
DR_0040 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Null> <Nutt> <Null>
DR_0041 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Null> <Nutt> <Null>
DR_0042 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Nutt> <Nutt>
DR_0043 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Nutt>
DR_0044 N A Fair orBetter Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Nutt>
DR_0045 N A Fair or Better Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Nutt>
DR_0046 N A I Fair or Better Some cross slopes above 2%and stamps for each driveway transition <Nutt> <Null> <Null>
DR_0047 N C Very Poor Cross slopes exceed 10%with steep side flares <Nutt> <Nutt> <Null>
DR 0048 N C Very Poor Cross slopes exceed 10%with steep side flares <Null> <Nutt> <Null>
DR_0049 N B Poor Mostly level with pedestrian access route-olderinfrastructure <Null> 36to>48" <Null>
DR_0050 N B Poor Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0051 N A Fair orBetter Mostlylevelwithpedestrianaccessroute-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0052 N A FairorBetter Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0053 N JA IFairorBetter I Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
December 2024 Page 1 of 3
TSI_Driveway_ID SW_ADA_Compliance Grade Condition Notes TSI_Driveway_Photo_ID Width Cross-Slope
DR_0054 N A Fair or Better Mostlylevelwithpedestrianaccessroute-olderinfrastructure <Null> <Nutt> <Null>
DR_0055 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0056 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure DR_0056.jpg <Nutt> <Nutt>
DR_0057 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR 0058 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0059 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Nutt> <Null> <Nutt>
DR_0060 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0061 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Null>
DR_0062 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Nutt>
DR_0063 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Null>
DR_0064 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0065 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0066 N A Fair or Better I Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Null>
DR_0067 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0068 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Nutt> <Nutt> <Nutt>
DR_0069 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Nutt> <Nutt> <Nutt>
DR_0070 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Nutt> <Nutt> <Nutt>
DR_0071 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Nutt> <Null> <Nutt>
DR_0072 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0073 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Nutt>
DR_0074 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Null>
DR_0075 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Nutt>
DR_0076 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Null>
DR_0077 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0078 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0079 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0080 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nulb <Null> <Null>
DR_0081 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Null>
DR_0082 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0083 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0084 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0085 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0086 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Null>
DR_0087 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Null>
DR_0088 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0089 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0090 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0091 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0092 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0093 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0094 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Null>
DR_0095 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0096 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Null>
DR_0097 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Null>
DR_0098 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0099 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0100 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Null> <Nutt> <Nutt>
DR_0301 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0102 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0103 N A Fair or Better I Mostly level with pedestrian access route-alder infrastructure <Nutt> <Nutt> <Nutt>
DR_0104 N A Fair or Better Mostly11 velwithpedestrianaccessroute-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0105 N A Fair or Better Mostly level with pedestrian access route-alder infrastructure <Nutt> <Nutt> <Nutt>
DR_0106 N JA Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Null>
December 2024 Page 2 of 3
TSI_Driveway_ID SW_ADA_Comptiance Grade Condition Notes TSI_Driveway_Photo_ID Width Cross-Slope
DR_0107 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Null>
DR_0108 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0109 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Nutt>
DR_0110 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutl> <Null> <Nutt>
DR_0111 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0112 IN A Fair or Better 1 Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutl> <Nutt>
DR_0113 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0114 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0115 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0116 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0117 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0118 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Null>
DR_0119 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0120 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0121 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0122 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0123 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0124 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0125 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Null> <Nutt> <Null>
DR_0126 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0127 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Null>
DR_0128 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0129 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0130 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Nutt> <Nutt>
DR_0131 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Nutt>
DR_0132 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0133 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0134 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0135 N A Fair or Better Mostlylevelwithpedestrianaccessroute-olderinfrastructure <Null> <Null> <Null>
DR_0136 N A Fair or Better Mostly level with pedestrian access route-older infrastructure <Nutt> <Nutt> <Nutt>
DR_0137 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0138 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Null> <Nutt>
DR_0139 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> <Null> <Nutt>
DR_0140 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0141 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> <Null>
DR_0142 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> I<Nutt> <Null>
DR_0143 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Null> <Nutt> J<Null>
DR_0144 N A Fair or Better Mostly level with pedestrian access route-olderinfrastructure <Nutt> I<Null> I<Nutt>
DR_0145 IN A Fair or Better Mostly level with pedestrian access route-older infrastructure <Nutt> I<Null> <Nutt>
December2024
Page 3 of 3
Public Right-of-Way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
Z;0 N C,
YIV
_ y
Appendix C3
WSDOT Standard Plans for Driveway Interface with Sidewalks
December 2024
Prepared by
' Transportation Solutions
INNOVATIVE I PRACTICAL I EQUITABLE
BROOMED (SEE NOTE 1) _- .VARIES(SEE CONTRACT)
FINISH(TYP.) _ GROOMED
31W(IN)EXPANSION JOINT DRIVEWAY
CEMENT CONC.PEDESTRIAN CURB(TYP.) SEE STANDARD PLAN F-70.10 (SEE NOTE 1) FINISH(TYP.) ENTRANCE
(NMEN SPECIFIED IN CONTRACT)- SIDEWALK
SEE STANDARD PLAN F40.12
3I8"(IN)EXPANSION JOINT (TYP)
3"(IN)R._ (TYP.)`SEE STANDARD - CEMENT CONC.SIDEWALK CEMENT CONCRETE
(TYP.) PLAN F-30.10 SIDEWALK
7771-7 —_ MATCH SIDEWALK WIDTH
(SEE CONTRACT)
A *� A (SEE CONTRACT)
1
DRIVEWAY
PLAN VIEW CEMENT CONCRETE CURB _
B CEMENT CONCRETE AND GUTTER(SEE NOTE 3) 5'-0-_ 7.8" TAPER(TYPJ `. DRIVEWAY ENTRANCE
TYPE 1 CURB AND GUTTER NOTES (TYP.) ~1(TYP.)
PLAN VIEW - SIDE SLOPE(TYP.)
(SEE NOTE 3)
1. When the driveway width exceeds 15'(ft),construct a full depth TYPE 2
15'MAX.(SEE NOTE 8) VARIES 15'MAX.(SEE NOTE 6) expansion joint with 3/6"(in)joint filler along the driveway centerline. 112"(IN)LIP BETWEEN
GRADE (TYP.) (SEE CONTRACT) (TYP.) See Standard Plan F-30.10.Construct expansion joints parallel ROADWAY GUTTER
BREAK GRADE GRADE BREAK- with the Centerline as required at 15'(ft)maximum spacing when AND CURB SEE
* BREAK NOT STEEPER THAN *,k :, driveway widths exceed 30' R g (SEE CONTRACT) (SEE CONTRACT) CONTRACT PLANS
ROA_D GRADE y ( )•
2. See Standard Plan F-30.10 for sidewalk details. 1n"(IN)R.(TYP.)
., e •a. .,. ., ''.,.'. " '• DEPRESSED CURB AND
PEDESTRIAN RAMP- �. PEDESTRIAN RAMP 3. Curb and Gutter shown;see the Contract Plans for the b GUTTER(SEE NOTE 3)
,D 1 curb design specified.See Standard Plan F-10.12 for
CEMENT CONCRETE Curb Details. /
SIDEWALK(TYP,) SECTION O - are"(IN)EXPANSION JOINT(TYP.)- DRIVEWAY J
SEE STANDARD PLAN F-30.10 4. Avoid placing drainage structures,junction boxes (SEE NOTE 7) SIDEWALK- DRIVEWAY RAMP
or other Obstructions in front of driveway entrances. 318"ON)EXPANSION JOINT(TYP.)i -
DP BETWEEN S. Where BREAK'is called out,the entire length of the SEE STANDARD PLAN F-30.10 SECTION
ROAD
O
ROADD S
WAY GUTTER "GRADE BREA lldth
9
(SEE CONTRACT) - (SEE CONTRACT) AND CURB(OR SEE line between the two adjacent surface planes shall be flush.
- CONTRACT)
tr2"ON)R. 6. The Pedestrian Ramp length is not required to exceed15 feet LEGEND
DEPRESSED CURB (unless otherwise shown in the Contract Plans).When applying - — SLOPE IN EITHER DIRECTION
(SEE CONTRACT) n AND GUTTER
the 15-foot max.length(measured from back of sidewalk)the
LS%OR FLATTER RECOMMENDED FOR
(SEE NOTE 3) running slope of the pedestrian ram is allowed to exceed 8.3°h. >AC
OR-IVEWAY
P DESIGN/FORMWORK(2%MAX.)
Use a single constant slope from bottom of ramp to top of �T
DRIVEWAY RAMP \ ramp to match into the sidewalk over a horizontal distance * * 7.5%OR FLATTER RECOMMENDED FOR SCOT wASy
3ME(IN)EXPANSION JOINT(TYR)- Of 15 feet. (SEE N(FORMWORK(8.3%MAX.) �4,
- SEE STANDARD PLAN F-30.10 (SEE NOTE 8) y0
(SEE NOTE 7) 7. Beyond limits shown.Pay item does not include driveway.
$ SECTION OB See Contract Plans.
"CEMENT CONCRETE DRIVEWAY
_ -ENTRANCE TYPE 2"PAY OMITS
W "CEMENT CONCRETE DRIVEWAY O CONTRACTION JOINT(TYP.)-SEE STANDARD PLAN F-30.10 �0 "P 28ra0 O
u_ ENTRANCE TYPE 1"PAY OMITS FOR RAMP LENGTHS GREATER THAN 8'-0"PROVIDE co `�01 STBp$ \�
CONTRACTION JOINT EQUALLY SPACED 4'-0"MIN.OC. s'r�ONA L 4'�G
m ..........
DRIVEWAY L
._.:� -
(SEE NOTE 7) DRIVEWAY
DRIVEWAY_
(SEE NOTE 7) CEMENT CONCRETE
DRIVEWAY ENTRANCE
CL.aaoo CONCRETE _ CL.STANDARD
CONCRETE _ TYPES 1, 2, 3, 8. 4
PER STANDARD SPEC.408.3 STANDARD PLAN F-80.10-04
PER STANDARD SPEC.6-0a.7
SHEET 1 OF 2 SHEETS
APPROVED FOR PUBLICATION
ISOMETRIC VIEW -� }'ISOMETRIC VIEW TIEI-N E-Ell
TYPE 1 -PAY LIMITS TYPE 2�-PAY LIMITS 0 :TIE
CEMENT \\4 MATCH SIDEWALK WIDTH
CONCRETE P (SEE CONTRACT) — -
SIDEWALK \ � �MATCH SIDEWALK WIDTH �
(SEE CONTRACT) 8'-0" VARIES B"0"
(SEE CONTRACT)
318"(IN)EXPANSION JOINT(TYP.)- GROOMED
\� p • - / SEE STANDARD PLAN F-30.10 p FINISH TYP.
u P 0 0 )
..
w 1
w
A m
v I
BUFFER STRIP(TYP.) \ (SEE NOTE 1) T-B" 2'-6" CEMENT CONCRETE DRIVEWAY ENTRANCE (SEE NOTE 1)—
CEMENT CONCRETE
E (TYP) (TYP) - CURB AND GUTTER SIDE SLOPE(TYP.) F CURB AND GUTTER
(SEE NOTE 3) (SEE NOTE 3)
PLAN VIEW PLAN VIEW
o TYPE 3 s of S SLOPE(TYP.)VEWAY TYPE 4
W \' THIS ENTRANCE TYPE SHALL NOT BE USED ALONG A PEDESTRIAN ROUTE
LL I
I
Z5m
MATCH SIDEWALK WIDTH _(SEE CONTRACT) (SEE CONTRACT)__
(SEE CONTRACT)
DRIVEWAY 4 m 12"(IN)UP BETWEEN ROADWAY io 1/2"(IN)UP BETWEEN ROADWAY
(SEE NOTE 7) \ b J GUTTER AND CURB(OR SEE 12"(IN)R.(TYP.)-
i \ CONTRACT) �D�- CONTRACT)GUTTER AND CUR ( SEE
Z` .. _ .................
SIDEWALK DRIVEWAY
DRIVEWAY DEPRESSED (SEE NOTE 7) DRIVEWAY
3/B"(IN)EXPANSION JOINT(TYP.)- SSED
RAMP CURB AND GUTTER RAMP SECTION OF - CURB DEPRANDGUTTER
SEE STANDARD PLAN F-30.10
(SEE NOTE 3) (SEE NOTE 3)
SECTION OE
VT
�� To
"CEMENT CONCRETE DRIVEWAY
ENTRANCE TYPE 3"PAY LIMIT °" .o
"CEMENT CONCRETE DRIVEWAY
DRIVEWAY ENTRANCE TYPE 4"PAY LIMIT 90 xaseo O
(SEE NOTE 7) A� A�GISTS Rs \�
CL.4000 CONCRETE _ � ,. �SIDNAL e�G
PER STANDARD SPEC.84ML3 DRIVEWAY —
(SEE NOTE 7)
CEMENT CONCRETE
CL.4000 CONCRETE DRIVEWAY ENTRANCE
PER STANDARD SPEC.6-06.7 TYPES 1, 2, 3, &4
STANDARD PLAN F-80.10-04
•• SHEET 2 OF 2 SHEETS
/ APPROVED FOR PUBLICATION
ISOMETRIC VIEW /ISOMETRIC VIEW
TYPE 3-PAY LIMITS TYPE 4-PAY LIMITS ldft
STATE DE-E-EER
r Wmhinqten Ste D".m .n\.1 Tran.PanoNen
Public Right-of-Way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
ON �
IN
Appendix Appendix C4
ADA Barrier Removal Cost Estimates
December 2024
Prepared by
' Transportation Solutions
INNOVATIVEI PRACTICAL I EQUITABLE
Transportation Solutions
Planning Level Cost Estimate
Project: Jefferson County Date: 12/14/24
Design Option: Typical Curb Ramp Removal and Replacement Prepared by: VLS
Length: 15 feet
Description: Replace non-compliant curb ramp
Assumptions: Drainage improvements not included.Undergrounding of utilities not included.ROW costs excluded.
Preparation Structures
1 Mobilization $900.00 50-53 Retaining Walls $0.00
2-4 Preparation Items $700.00 54 Bridge Structure $0.00
5-12 Removal Items $365.00 Structure Subtotal $0.00
Preparation Subtotal $1,965.00
TESC and Landscaping
Grading 55-57 TESC $200.00
13-14 Roadway Grading $155.00 58-62 Plantings $0.00
15-18 Roadway Foundation $200.00 63-64 Irrigation $0.00
19-24 Utility Excavation $0.00 TESC and Landscaping Subtotal $200.00
Grading Subtotal $355.00
Traffic
Storm Drainage 65-74 Markings and Signing $0.00
25-36 Conveyance System $0.00 75-78 Guardrail/Handrail $0.00
37 Culvert/Stream Crossing $0.00 79-83 Traffic Signal System $0.00
38 Detention/Water Quality Facility $0.00 84-86 Illumination System $0.00
Storm Drainage Subtotal $0.00 87-92 Traffic Control $2,200.00
Traffic Subtotal $2,200.00
Paving
39-41 Hot Mix Asphalt Pavement $310.00 F Other Items
HMA Subtotal $310.00 93-94 Utility Relocates $0.00
95-97 Misc.Construction $500.00
Other Items Subtotal $500.00
Concrete
42-44 Sidewalks,Ramps,Driveways $3,500.00
45-47 Curbs and Gutters $600.00
48-49 Concrete Roadway/Roundabout $0.00
Concrete Subtotal $4,100.00
CONSTRUCTION SUBTOTAL $9,630.00
CONTINGENCY 40% $3,860.00
CONSTRUCTION(CN)SUBTOTAL $13,490.00
Low High
PE $3,000 $7,000 DESIGN ENGINEERING 15% $2,030.00
ROW $0 $0 CONSTRUCTION ENGINEERING 12% $1,620.00
CN $10,000 $21,000 PROJECT ADMINISTRATION 5% $680.00
Total $13,000 $28,000 ENGR.AND ADMIN.(PE)SUBTOTAL $4,330.00
Project Cost Summary includes a range of reported ENVIRONMENTAL ENGINEERING(PE) 2% $270.00
project costs for this planning level estimate,which is ENVIRONMENTAL MITIGATION(CN) 2% $270.00
based upon 10%design information(scoping row). ENVIRONMENTAL SUBTOTAL $540.00
Low is 30%below and high is 50%above the
estimated cost category.Reference:WSDOT Cost RIGHT-OF-WAY(ROW)SUBTOTAL $0.00
Estimating Manual for Projects,Page 4-10,January
2023. TOTAL PROJECT COST Year 2024 $18,360.00
Typical Sidewalk Sum
Curb Ramp VLS updated 12142024 Page 1 of 1 Printed:12/14/2024
Transportation Solutions
Planning Level Cost Estimate
Project: Jefferson County Date: 12/14/24
Design Option: Typical Sidewalk Removal and Replacement Prepared by: VLS
Length: 100 feet
Description: Construct curb,gutter,and 6-foot sidewalk for the distance listed above.
Assumptions: Drainage improvements not included.Undergrounding of utilities not included. ROW costs excluded.
Preparation I Structures
1 Mobilization $2,500.00 50-53 Retaining Walls $0.00
2-4 Preparation Items $2,400.00 54 Bridge Structure $0.00
5-12 Removal Items $2,465.00 Structure Subtotal $0.00
Preparation Subtotal $7,365.00
TESC and Landscaping
Grading 55-57 TESC $400.00
13-14 Roadway Grading $670.00 58-62 Plantings $0.00
15-18 Roadway Foundation $835.00 63-64 Irrigation $0.00
19-24 Utility Excavation $0.00 TESC and Landscaping Subtotal $400.00
Grading Subtotal $1,505.00
Traffic
Storm Drainage 65-74 Markings and Signing $0.00
25-36 Conveyance System $0.00 75-78 Guardrail/Handrail $0.00
37 Culvert/Stream Crossing $0.00 79-83 Traffic Signal System $0.00
38 Detention/Water Quality Facility $0.00 84-86 Illumination System $0.00
Storm Drainage Subtotal $0.00 87-92 Traffic Control $7,000.00
Traffic Subtotal $7,000.00
Paving
39-41 Hot Mix Asphalt Pavement $1,550.00 F Other Items
HMA Subtotal $1,550.00 93-94 Utility Relocates $0.00
95-97 Misc.Construction $500.00
Other Items Subtotal $500.00
Concrete
42-44 Sidewalks,Ramps,Driveways $4,355.00
4547 Curbs and Gutters $4,000.00
48-49 Concrete Roadway/Roundabout $0.00
Concrete Subtotal $8,355.00
CONSTRUCTION SUBTOTAL $26,675.00
CONTINGENCY 40% $10,670.00
CONSTRUCTION(CN)SUBTOTAL $37,345.00
Low High
PE $10,000 $21,000 DESIGN ENGINEERING 15% $5,610.00
ROW $0 $0 CONSTRUCTION ENGINEERING 15% $5,610.00
CN $26,000 $57,000 PROJECT ADMINISTRATION 5% $1,870.00
Total $36,000 $78,000 ENGR.AND ADMIN.(PE)SUBTOTAL $13,090.00
Project Cost Summary includes a range of reported ENVIRONMENTAL ENGINEERING(PE) 2% $750.00
project costs for this planning level estimate,which is ENVIRONMENTAL MITIGATION(CN) 1% $380.00
based upon 10%design information(scoping row). ENVIRONMENTAL SUBTOTAL $1,130.00
Low is 30%below and high is 50%above the
estimated cost category.Reference:WSDOT Cost RIGHT-OF-WAY(ROW)SUBTOTAL $0.00
Estimating Manual for Projects,Page 4-10,January
2023, TOTAL PROJECT COST Year 2024 $51,565.00
Typical Sidewalk Sum
Sidewalk No Drainage VLS updated 6 FT SW Page 1 of 1 Printed:12/14/2024
Transportation Solutions
Planning Level Cost Estimate —..- j ppAC iCAL I EQUITABLE
Project: Jefferson County Date: 12/14/24
Design Option: Typical Sidewalk Removal and Replacement Prepared by: VLS
Length: 100feet
Description: FCo nstruct curb,gutter,and 6-foot sidewalk for the distance listed above.
Assumptions: Drainage improvements included.Undergrounding of utilities not included.ROW costs excluded.
Preparation I Structures
1 Mobilization $3,600.00 50-53 Retaining Walls $0.00
2-4 Preparation Items $2,600.00 54 Bridge Structure $0.00
5-12 Removal Items $1,840.00 Structure Subtotal $0.00
Preparation Subtotal $8,040.00
TESC and Landscaping
Grading 55-57 TESC $600.00
13-14 Roadway Grading $670.00 58-62 Plantings $0.00
15-18 Roadway Foundation $835.00 63-64 Irrigation $0.00
19-24 Utility Excavation $0.00 TESC and Landscaping Subtotal $600.00
Grading Subtotal $1,505.00
Traffic
Storm Drainage 65-74 Markings and Signing $0.00
25-36 Conveyance System $11,200.00 75-78 Guardrail/Handrail $0.00
37 Culvert/Stream Crossing $0.00 79-83 Traffic Signal System $0.00
38 Detention/Water Quality Facility $0.00 84-86 Illumination System $0.00
Storm Drainage Subtotal $11,200.00 87-92 Traffic Control $7,000.00
Traffic Subtotal $7,000.00
Paving
39-41 Hot Mix Asphalt Pavement $1,550.00 Other Items
HMA Subtotal $1,550.00 93-94 Utility Relocates $0.00
95-97 Misc.Construction $500.00
Other Items Subtotal $500.00
Concrete
42-44 Sidewalks,Ramps,Driveways $4,355.00
45-47 Curbs and Gutters $4,000.00
48-49 Concrete Roadway/Roundabout $0.00
Concrete Subtotal $8,355.00
CONSTRUCTION SUBTOTAL $38,750.00
CONTINGENCY 40% $15,500.00
CONSTRUCTION(CN)SUBTOTAL $54,250.00
Low High
PE $14,000 $30,000 DESIGN ENGINEERING 15% $8,140.00
ROW $0 $0 CONSTRUCTION ENGINEERING 15% $8,140.00
CN $38,000 $82,000 PROJECT ADMINISTRATION 5% $2,720.00
Total $52,000 $112,000 ENGR.AND ADMIN.(PE)SUBTOTAL $19,000.00
Project Cost Summary includes a range of reported ENVIRONMENTAL ENGINEERING(PE) 2% $1,090.00
project costs for this planning level estimate,which is ENVIRONMENTAL MITIGATION(CN) 1% $550.00
based upon 10%design information(scoping row). ENVIRONMENTAL SUBTOTAL $1,640.00
Low is 30%below and high is 50%above the
estimated cost category.Reference:WSDOT Cost RIGHT-OF-WAY(ROW)SUBTOTAL $0.00
Estimating Manual for Projects,Page 4-10,January
2023. TOTAL PROJECT COST Year 2024 $74,890.00
Typical Sidewalk Sum
Sidewalk 6-Feet With Drainage VLS updated 12142024 Page 1 of 1 Printed:12/14/2024
Transportation Solutions
Planning Level Cost Estimate
Project: Jefferson County Date: 12/14/24
Design Option: Type 1 Driveway Prepared by: VLS
Length: 20 feet
Description: Construct Type 1 Driveway for the width listed above.
Assumptions: Drainage improvements not included.Undergrounding of utilities not included.ROW costs excluded.
Preparation Structures
1 Mobilization $1,300.00 50-53 Retaining Walls $0.00
2-4 Preparation Items $2,200.00 54 Bridge Structure $0.00
5-12 Removal Items $745.00 Structure Subtotal $0.00
Preparation Subtotal $4,245.00
TESC and Landscaping
Grading 55-57 TESC $200.00
13-14 Roadway Grading $290.00 58-62 Plantings $0.00
15-18 Roadway Foundation $435.00 63-64 Irrigation $0.00
19-24 Utility Excavation $0.00 TESC and Landscaping Subtotal $200.00
Grading Subtotal $725.00
Traffic
Storrs Drainage 65-74 Markings and Signing $0.00
25-36 Conveyance System $0.00 75-78 Guardrail/Handrail $0.00
37 Culvert/Stream Crossing $0.00 79-83 Traffic Signal System $0.00
38 Detention/Water Quality Facility $0.00 84-86 Illumination System $0.00
Storm Drainage Subtotal $0.00 87-92 Traffic Control $3,400.00
Traffic Subtotal $3,400.00
Paving
39-41 Hot Mix Asphalt Pavement $1,550.00 F Other Items
HMA Subtotal $1,550.00 93-94 Utility Relocates $0.00
95-97 Misc.Construction $500.00
Other Items Subtotal $500.00
Concrete
42-44 Sidewalks,Ramps,Driveways $2,000.00
45-47 Curbs and Gutters $1,600.00
48-49 Concrete Roadway/Roundabout $0.00
Concrete Subtotal $3,600.00
CONSTRUCTION SUBTOTAL $14,220.00
CONTINGENCY 40% $5,690.00
CONSTRUCTION(CN)SUBTOTAL $19,910.00
Low High
PE $5,000 $11,000 DESIGN ENGINEERING 15% $2,990.00
ROW $0 $0 CONSTRUCTION ENGINEERING 15% $2,990.00
CN $14,000 $30,000 PROJECT ADMINISTRATION 5% $1,000.00
Total $19,000 $41,000 ENGR.AND ADMIN.(PE)SUBTOTAL $6,980.00
Project Cost Summary includes a range of reported ENVIRONMENTAL ENGINEERING(PE) 2% $400.00
project costs for this planning level estimate,which is ENVIRONMENTAL MITIGATION(CN) 1% $200.00
based upon 10%design information(scoping row). ENVIRONMENTAL SUBTOTAL $600.00
Low is 30%below and high is 50%above the
estimated cost category.Reference:WSDOT Cost RIGHT-OF-WAY(ROW)SUBTOTAL $0.00
Estimating Manual for Projects,Page 4-10,January
2023. TOTAL PROJECT COST Year 2024 $27,490.00
Typical Sidewalk Sum
Type 1 Driveway VLS updated 12142024 Page 1 of 1 Printed:12/14/2024
Transportation Solutions
Planning Level Cost Estimate
Project: Jefferson County Date: 12/14/24
Design Option: Type 2 Driveway Prepared by: VLS
Length: 20 feet
Description: Construct Type 2 Driveway for the width listed above.
Assumptions: Drainage improvements not included.Undergrounding of utilities not included.ROW costs excluded.
Preparation I Structures
1 Mobilization $1,500.00 50-53 Retaining Walls $0.00
2-4 Preparation Items $2,300.00 54 Bridge Structure $0.00
5-12 Removal Items $650.00 Structure Subtotal $0.00
Preparation Subtotal $4,450.00
TESC and Landscaping
Grading 55-57 TESC $300.00
13-14 Roadway Grading $245.00 58-62 Plantings $0.00
15-18 Roadway Foundation $390.00 63-64 Irrigation $0.00
19-24 Utility Excavation $0.00 TESC and Landscaping Subtotal $300.00
Grading Subtotal $635.00
Traffic
Storm Drainage 65-74 Markings and Signing $0.00
25-36 Conveyance System $0.00 75-78 Guardrail/Handrail $0.00
37 Culvert/Stream Crossing $0.00 79-83 Traffic Signal System $0.00
38 Detention/Water Quality Facility $0.00 84-86 Illumination System $0.00
Storm Drainage Subtotal $0.00 87-92 Traffic Control $3,400.00
Traffic Subtotal $3,400.00
Paving
39-41 Hot Mix Asphalt Pavement $1,550.00 Other Items
HMA Subtotal $1,550.00 93-94 Utility Relocates $0.00
95-97 Misc.Construction $500.00
Other Items Subtotal $500.00
Concrete
42-44 Sidewalks,Ramps,Driveways $3,800.00
45-47 Curbs and Gutters $1,400.00
48-49 Concrete Roadway/Roundabout $0.00
Concrete Subtotal $5,200.00
CONSTRUCTION SUBTOTAL $16,035.00
CONTINGENCY 40% $6,420.00
CONSTRUCTION(CN)SUBTOTAL $22,455.00
Low High
PE $6,000 $12,000 DESIGN ENGINEERING 15% $3,370.00
ROW $0 $0 CONSTRUCTION ENGINEERING 15% $3,370.00
CN $16,000 $34,000 PROJECT ADMINISTRATION 5% $1,130.00
Total $22,000 $46,000 ENGR.AND ADMIN.(PE)SUBTOTAL $7,870.00
Project Cost Summary includes a range of reported ENVIRONMENTAL ENGINEERING(PE) 2% $450.00
project costs for this planning level estimate,which is ENVIRONMENTAL MITIGATION(CN) 1% $230.00
based upon 10%design information(scoping row). ENVIRONMENTAL SUBTOTAL $680.00
Low is 30%below and high is 50%above the
estimated cost category.Reference:WSDOT Cost RIGHT-OF-WAY(ROW)SUBTOTAL $0.00
Estimating Manual for Projects,Page 4-10,January
2023. TOTAL PROJECT COST Year 2024 $31,005.00
Typical Sidewalk Sum
Type 2 Driveway VLS updated 12142024 Page 1 of 1 Printed:12/14/2024
�" Transportation Solutions
Planning Level Cost Estimate ' NNO-11-V 1 1.11. 1 ...
Project: Jefferson County Date: 12/14/24
Design Option: Type 3 Driveway Prepared by: VLS
Length: 20feet
Description: Construct Type 3 Driveway for the width listed above.
Assumptions: Drainage improvements not included.Undergrounding of utilities not included. ROW costs excluded.
Preparation Structures
1 Mobilization $1,300.00 50-53 Retaining Walls $0.00
2-4 Preparation Items $2,200.00 54 Bridge Structure $0.00
5-12 Removal Items $555.00 Structure Subtotal $0.00
Preparation Subtotal $4,055.00
TESC and Landscaping
Grading 55-57 TESC $200.00
13-14 Roadway Grading $245.00 58-62 Plantings $0.00
15-18 Roadway Foundation $390.00 63-64 Irrigation $0.00
19-24 Utility Excavation $0.00 TESC and Landscaping Subtotal $200.00
Grading Subtotal $635.00
Traffic
Storm Drainage 65-74 Markings and Signing $0.00
25-36 Conveyance System $0.00 75-78 Guardrail/Handrail $0.00
37 Culvert/Stream Crossing $0.00 79-83 Traffic Signal System $0.00
38 Detention/Water Quality Facility $0.00 84-86 Illumination System $0.00
Storm Drainage Subtotal $0.00 87-92 Traffic Control $3,400.00
Traffic Subtotal $3,400.00
Paving
39-41 Hot Mix Asphalt Pavement $1,550.00 Other Items
HMA Subtotal $1,550.00 93-94 Utility Relocates $0.00
95-97 Misc.Construction $500.00
Other Items Subtotal $500.00
Concrete
42-44 Sidewalks,Ramps,Driveways $2,800.00
45-47 Curbs and Gutters $1,000.00
48-49 Concrete Roadway/Roundabout $0.00
Concrete Subtotal $3,800.00
CONSTRUCTION SUBTOTAL $14,140.00
CONTINGENCY 40% $5,660.00
CONSTRUCTION(CN)SUBTOTAL $19,800.00
Low High
PE $5,000 $11,000 DESIGN ENGINEERING 15% $2,970.00
ROW $0 $0 CONSTRUCTION ENGINEERING 15% $2,970.00
CN $14,000 $30,000 PROJECT ADMINISTRATION 5% $990.00
Total $19,000 $41,000 ENGR.AND ADMIN.(PE)SUBTOTAL $6,930.00
Project Cost Summary includes a range of reported ENVIRONMENTAL ENGINEERING(PE) 2% $400.00
project costs for this planning level estimate,which is ENVIRONMENTAL MITIGATION(CN) 1% $200.00
based upon 10%design information(scoping row). ENVIRONMENTAL SUBTOTAL $600.00
Low is 30%below and high is 50%above the
estimated cost category.Reference:WSDOT Cost RIGHT-OF-WAY(ROW)SUBTOTAL $0.00
Estimating Manual for Projects,Page 4-10,January
2023. TOTAL PROJECT COST Year 2024 $27,330.00
Typical Sidewalk Sum
Type 3 Driveway VLS updated 12142024 Page 1 of 1 Printed:12/14/2024
Public Right-of-way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
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Appendix C5
DOJ/DOT Joint ADA Curb Ramps Memo and Supplement
December 2024
Prepared by
Opto Transportation Solutions
INNOVATIVE IQI[ Ii� nl FQIiRA6 F
U.S.Department of Justice
Civil Rights Division rdwlw�
U.S. Department of Transportation
Disability Rights Section Federal Highway Administration
Department of Justice/Department of Transportation
Joint Technical Assistance! on the Title II of the
Americans with Disabilities Act Requirements to
Provide Curb Ramps when Streets, Roads, or Highways
are Altered through Resurfacing
Title II of the Americans with Disabilities Act(ADA)requires that state and local governments ensure that persons with
disabilities have access to the pedestrian routes in the public right of way.An important part of this requirement is the
obligation whenever streets, roadways,or highways are altered to provide curb ramps where street level pedestrian
walkways cross curbs.2 This requirement is intended to ensure the accessibility and usability of the pedestrian walkway
for persons with disabilities.
An alteration is a change that affects or could affect the usability of all or part of a building or facility.! Alterations of
streets,roads,or highways include activities such as reconstruction,rehabilitation,resurfacing,widening,and projects of
similar scale and effect 4 Maintenance activities on streets,roads, or highways, such as filling potholes,are not
alterations.
Without curb ramps, sidewalk travel in urban areas can be dangerous,difficult,or even impossible for people who use
wheelchairs, scooters, and other mobility devices. Curb ramps allow people with mobility disabilities to gain access to
the sidewalks and to pass through center islands in streets. Otherwise,these individuals are forced to travel in streets and
roadways and are put in danger or are prevented from reaching their destination; some people with disabilities may
simply choose not to take this risk and will not venture out of their homes or communities.
Because resurfacing of streets constitutes an alteration under the ADA,it triggers the obligation to provide curb ramps
where pedestrian walkways intersect the resurfaced streets. See Kinney v. Yerusalim, 9 F 3d 1067 (3rd Cir. 1993). This
obligation has been discussed in a variety of technical assistance materials published by the Department of Justice
beginning in 1994.5 Over the past few years, state and local governments have sought further guidance on the scope of
the alterations requirement with respect to the provision of curb ramps when streets,roads or highways are being
resurfaced. These questions have arisen largely due to the development of a variety of road surface treatments other
than traditional road resurfacing,which generally involved the addition of a new layer of asphalt. Public entities have
asked the Department of Transportation and the Department of Justice to clarify whether particular road surface
treatments fall within the ADA definition of alterations,or whether they should be considered maintenance that would
not trigger the obligation to provide curb ramps. This Joint Technical Assistance addresses some of those questions.
Where must curb ramps be provided?
Generally,curb ramps are needed wherever a sidewalk or other pedestrian walkway crosses a curb. Curb ramps must be
located to ensure a person with a mobility disability can travel from a sidewalk on one side of the street, over or through
any curbs or traffic islands,to the sidewalk on the other side of the street. However,the ADA does not require
installation of ramps or curb ramps in the absence of a pedestrian walkway with a prepared surface for pedestrian use.
Nor are curb ramps required in the absence of a curb, elevation,or other barrier between the street and the walkway.
•♦MICH lA l O3111&A%.1Lg%.UHMIUCI GU LV Uko all alLUI ALIUH 4
Resurfacing is an alteration that triggers the requirement to add curb ramps if it involves work on a street or roadway
spanning from one intersection to another, and includes overlays of additional material to the road surface,with or
without milling. Examples include,but are not limited to the following treatments or their equivalents: addition of a
new layer of asphalt,reconstruction,concrete pavement rehabilitation and reconstruction,open-graded surface course,
micro-surfacing and thin lift overlays, cape seals, and in-place asphalt recycling.
What kinds of treatments constitute maintenance rather than an alteration?
Treatments that serve solely to seal and protect the road surface,improve friction,and control splash and spray are
considered to be maintenance because they do not significantly affect the public's access to or usability of the road.
Some examples of the types of treatments that would normally be considered maintenance are: painting or striping
lanes,crack filling and sealing, surface sealing, chip seals, slurry seals, fog seals,scrub sealing,joint crack seals,joint
repairs, dowel bar retrofit, spot high-friction treatments, diamond grinding,and pavement patching. In some cases,the
combination of several maintenance treatments occurring at or near the same time may qualify as an alteration and
would trigger the obligation to provide curb ramps.
What if a locality is not resurfacing an entire block,but is resurfacing a crosswalk by itself?
Crosswalks constitute distinct elements of the right-of-way intended to facilitate pedestrian traffic. Regardless of
whether there is curb-to-curb resurfacing of the street or roadway in general,resurfacing of a crosswalk also requires the
provision of curb ramps at that crosswalk.
1 The Department of Justice is the federal agency with responsibility for issuing regulations
implementing the requirements of title II of the ADA and for coordinating federal agency compliance
activities with respect to those requirements. Title II applies to the programs and activities of state and
local governmental entities.The Department of Justice and the Department of Transportation share
responsibility for enforcing the requirements of title II of the ADA with respect to the public right of way,
including streets,roads,and highways.
2 See 28 CFR 35.151(i)(1)(Newly constructed or altered streets,roads,and highways must contain curb
ramps or other sloped areas at any intersection having curbs or other barriers to entry from a street level
pedestrian walkway)and 35.151(i)(2)(Newly constructed or altered street level pedestrian walkways
must contain curb ramps or other sloped areas at intersections to streets,roads,or highways).
3 28 CFR 35.151(b)(1).
4 2010 ADA Accessibility Standards,section 106.5.
1 See 1994 Title II Technical Assistance Manual Supplement,Title II TA Guidance: The ADA and City
Governments:Common Problems;and ADA Best Practices Tool Kit for State and Local Governments:
Chapter 6,Curb Ramps and Pedestrian Crossings under Title II of the ADA,available at ada.gov.
The Americans with Disabilities Act authorizes the Department of Justice(the Department)to provide technical
assistance to individuals and entities that have rights or responsibilities under the Act. This document provides informal
guidance to assist you in understanding the ADA and the Department's regulations.
This guidance document is not intended to be a final agency action,has no legally binding effect,and may be rescinded
or modified in the Department's complete discretion, in accordance with applicable laws. The Department's guidance
documents, including this guidance,do not establish legally enforceable responsibilities beyond what is required by the
terms of the applicable statutes,regulations, or binding judicial precedent.
July 8,2013
yF "? U.S. Department of Justice
v� y:
V-1 Civil Rights Division U.S. Department of Transportation
Disability Rights Section Federal Highway Administration
QUESTIONS & ANSWERS
Supplement to the 2013 DOJ/DOT Joint Technical Assistance on the Title II of the
Americans with Disabilities Act Requirements To Provide Curb Ramps when Streets,
Roads, or Highways are Altered through Resurfacing
The Department of Justice (DOJ)/Department of Transportation (DOT) Joint Technical Assistance on the Title
11 of the Americans with Disabilities Act[ADA]Requirements to Provide Curb Ramps when Streets, Roads, or
Highways are Altered through Resurfacing (Joint Technical Assistance) was published on July 8, 2013. This
document responds to frequently asked questions that the Federal Highway Administration (FHWA) has
received since the technical assistance document was published. In order to fully address some questions,
the applicable requirements of Section 504 of the Rehabilitation Act of 1973 that apply to public entities
receiving Federal funding from DOT, either directly or indirectly, are also discussed. This document is not a
standalone document and should be read in conjunction with the 2013 Joint Technical Assistance.
Q1: When a pavement treatment is considered an alteration under the ADA and there is a curb ramp
at the juncture of the altered road and an existing sidewalk(or other prepared surface for pedestrian
use), but the curb ramp does not meet the current ADA Standards, does the curb ramp have to be
updated to meet the current ADA Standards at the time of the pavement treatment?
Al: It depends on whether the existing curb ramp meets the appropriate accessibility standard that was in
place at the time it was newly constructed or last altered.
When the Department of Justice adopted its revised title II ADA Regulations including the updated ADA
Standards for Accessible Design (2010 Standards,! as defined in 28 CFR 35.151), it specified that
"(e)lements that have not been altered in existing facilities on or after March 15, 2012, and that comply with
the corresponding technical and scoping specifications for those elements in either the 1991 Standards or in
the Uniform Federal Accessibility Standards (UFAS) ... are not required to be modified in order to comply with
the requirements set forth in the 2010 Standards." 28 C.F.R. 35.150(b)(2)(i). As a result of this "safe harbor"
provision, if a curb ramp was built or altered prior to March 15, 2012, and complies with the requirements for
curb ramps in either the 1991 ADA Standards for Accessible Design (1991 Standards, known prior to 2010 as
the 1991 ADA Accessibility Guidelines, or the 1991 ADAAG) or UFAS, it does not have to be modified to
comply with the requirements in the 2010 Standards. However, if that existing curb ramp did not comply with
either the 1991 Standards or UFAS as of March 15, 2012, then the safe harbor does not apply and the curb
ramp must be brought into compliance with the requirements of the 2010 Standards concurrent with the road
alteration. See 28 CFR 35.151(c) and (i).
NULe Mal. <ne requirernenl. in uie iyy i OLanuarus Lo inciuue ueLeCLauie warnings on Guru ramps was
suspended for a period between May 12, 1994, and July 26, 1998, and again between December 23, 1998,
and July 26, 2001. If a curb ramp was newly constructed or was last altered when the detectable warnings
requirement was suspended, and it otherwise meets the 1991 Standards, Title II of the ADA does not require
that the curb ramp be modified to add detectable warnings in conjunction with a road resurfacing alteration
project. See Question #14 however, for a discussion of the DOT Section 504 requirements, including
detectable warnings.
Q2: The Joint Technical Assistance states that "[r]esurfacing is an alteration that triggers the
requirement to add curb ramps if it involves work on a street or roadway spanning from one
intersection to another, and includes overlays of additional material to the road surface, with or
without milling." What constitutes "overlays of additional material to the road surface"with respect
to milling, specifically, when a roadway surface is milled and then overlaid at the same height(i.e., no
material is added that exceeds the height of what was present before the milling)?
A2: A project that involves milling an existing road, and then overlaying the road with material, regardless of
whether it exceeds the height of the road before milling, falls within the definition of"alteration" because it is a
change to the road surface that affects or could affect the usability of the pedestrian route (crosswalk). See
Kinney v. Yerusalim, 9 F.3d 1067 (3rd Cir. 1993). Alterations require the installation of curb ramps if none
previously existed, or upgrading of non-compliant curb ramps to meet the applicable standards, where there
is an existing pedestrian walkway. See also Question 8.
Q3: If a roadway resurfacing alteration project does not span the full width of the road, do I have to
put in curb ramps?
A3: It depends on whether the resurfacing work affects a pedestrian crosswalk. If the resurfacing affects the
crosswalk, even if it is not the full roadway width, then curb ramps must be provided at both ends of the
crosswalk. See 28 CFR 35.151(i).
Public entities should not structure the scope of work to avoid ADA obligations to provide curb ramps when
resurfacing a roadway. For example, resurfacing only between crosswalks may be regarded as an attempt to
circumvent a public entity's obligation under the ADA, and potentially could result in legal challenges.
If curb ramp improvements are needed in the vicinity of an alteration project, it is often cost effective to
address such needs as part of the alteration project, thereby advancing the public entity's progress in
meeting its obligation to provide program access to its facilities. See Question 16 for further discussion.
Q4: When a road alteration project triggers the requirement to install curb ramps, what steps should
public (State or local) entities take if they do not own the sidewalk right-of-way needed to install the
required curb ramps?
A4: The public entity performing the alteration is ultimately responsible for following and implementing the
ADA requirements specified in the regulations implementing title Il. At the time an alteration project is
scoped, the public entity should identify what ADA requirements apply and whether the public entity owns
sufficient right-of-way to make the necessary ADA modifications. If the public entity does not control sufficient
ngnr-oi-way, n sncuia seers ro acquire ine necessary ngni.-oi-way. ii a curnPiainr is ineu, one puUnc enuLy will
likely need to show that it made reasonable efforts to obtain access to the necessary right-of-way.
Q5: The Joint Technical Assistance is silent on when it becomes effective. Is there an effective date
for when States and local public entities must comply with the requirements discussed in the
technical assistance?
A5: The Joint Technical Assistance, as well as this Supplement to it, does not create any new obligations.
The obligation to provide curb ramps when roads are altered has been an ongoing obligation under the
regulations implementing title 11 of the ADA (28 CFR 35.151) since the regulation was initially adopted in
1991. This technical assistance was provided to respond to questions that arose largely due to the
development of a variety of road surface treatments, other than traditional road resurfacing, which generally
involved the addition of a new layer of asphalt. Although the Joint Technical Assistance was issued on July 8,
2013, public entities have had an ongoing obligation to comply with the alterations requirements of title II and
should plan to bring curb ramps that are or were part of an alteration into compliance as soon as possible.
Q6: Is the curb ramp installation work required to be a part of the Plans, Specifications and Estimate
package for an alteration project or can the curb ramp work be accomplished under a separate
contract?
A6: The curb ramp installation work can be contracted separately, but the work must be coordinated such that
the curb ramp work is completed prior to, or at the same time as, the completion of the rest of the alteration
work. See 28 CFR 35.151(i).
Q7: Is a curb ramp required for a sidewalk that is not made of concrete or asphalt?
A7: The Joint Technical Assistance states that "the ADA does not require installation of ramps or curb ramps
in the absence of a pedestrian walkway with a prepared surface for pedestrian use." A "prepared surface for
pedestrian use" can be constructed out of numerous materials, including concrete, asphalt, compacted soil,
decomposed granite, and other materials. Regardless of the materials used to construct the pedestrian
walkway, if the intent of the design was to provide access to pedestrians, then curb ramps must be
incorporated where an altered roadway intersects the pedestrian walkway. See 28 CFR 35.151(i).
Q8: If an existing curb ramp is replaced as part of a resurfacing alteration, is there an obligation to
address existing obstacles on the adjacent sidewalk at the same time?
A8: No. The Joint Technical Assistance addresses those requirements that are triggered when a public entity
alters a roadway where the roadway intersects a street level pedestrian walkway (28 CFR 35.151(i)). Public
entities are required to address other barriers on existing sidewalks, such as steep cross slopes or
obstructions, as part of their on-going program access and transition plan obligations under title II of the ADA
and Section 504 and in response to requests for reasonable modifications under the ADA or reasonable
accommodations under Section 504. See 28 CFR 35.105, 35.130(b)(7), and 35.150(d); see also 49 CFR
27.7(e), 27.11(c)(2).
09: Several pavement preservation treatment types are not listed in the technical assistance. If the
treatment type is not specifically on the list of maintenance treatments, is it an alteration?
Na: ivew treatments are aiways ueiny ueveiopea aria the uest pracuce is for the L,ny or Omer iucai puunc
entity conducting the work, the State transportation agency, and FHWA to work together to come to an
agreement on a reasonable determination of whether the unlisted treatment type is an alteration or
maintenance and document their decisions. If the new treatment can be deemed to be the equivalent of any
of the items listed as alterations, it is a reasonable interpretation that they are in fact alterations and should
be treated as such.
Q10: When does a combination of two or more `maintenance' treatments rise to the level of being an
alteration?
Al0: The list of the pavement types that are considered maintenance, as stated in the 2013 Joint Technical
Assistance document, are Chip Seals, Crack Filling and Sealing, Diamond Grinding, Dowel Bar Retrofit, Fog
Seals, Joint Crack Seals, Joint Repairs, Pavement Patching, Scrub Sealing, Slurry Seals, Spot High-Friction
Treatments, and Surface Sealing. The combination of two or more maintenance treatments may rise to the
level of being an alteration.
The best practice is for the City or other local public entity conducting the work, the State transportation
agency, and FHWA to work together to come to an agreement on a reasonable determination, document their
policies, and apply that determination consistently in their locality.
Q11: When will utility trench work require compliance with ADA curb ramp requirements?
Al1: The answer to this question depends on the scope and location of the utility trench work being done. If
the utility trench work is limited to a portion of the pavement, even including a portion of the crosswalk,
repaving necessary to cover the trench would typically be considered maintenance and would not require
simultaneous installation or upgrading of curb ramps. Public entities should note that the ADA requires
maintenance of accessible features, and as such, they must ensure that when the trench is repaved or other
road maintenance is performed, the work does not result in a lesser level of accessibility. See 28 CFR
35.133(a). If the utility work impacts the curb at a pedestrian street crossing where no curb ramp exists, the
work affecting the curb falls within the definition of"alteration," and a curb ramp must be constructed rather
than simply replacing the curb. See 28 CFR 35.151(b) and 35.151(i).
If a public entity is unsure whether the scope of specific trench work and repair/repaving constitutes an
alteration, the best practice is for the public entity to work together with the State transportation agency and
the FHWA Division to come to an agreement on how to consistently handle these situations and document
their decisions.
Q12: Is full-depth pavement patching considered maintenance?
Al 2: The answer to this question depends on the scope and location of the pavement patch. If the pavement
patch work is limited to a portion of the pavement, even including a portion of the crosswalk, patching the
pavement would typically be considered maintenance and would not require simultaneous installation or
upgrading of curb ramps. Public entities should note that the ADA requires maintenance of accessible
features, and as such, they should ensure that when the pavement is patched or other road maintenance is
performed, the work does not result in a lesser level of accessibility. See 28 CFR 35.133(a). If the pavement
paicrnny impaGUS Lne curd ai a peoeWlan SLreeL crossing wnere no curd ramp exists, ine worK aiiecuny Lne
curb falls within the definition of"alteration," and a curb ramp must be constructed rather than simply
replacing the curb. See 28 CFR 35.151(b) and 35.151(i).
If a public entity is unsure whether the scope of specific full-depth pavement patching constitutes an
alteration, the best practice is for the public entity to work together with the State transportation agency and
the FHWA Division to come to an agreement on how to consistently handle these situations and document
their decisions.
Q13: Do any other requirements apply to road alteration projects undertaken by public entities that
receive Federal financial assistance from DOT either directly or indirectly, even if such financial
assistance is not used for the specific road alteration project at issue?
Al3: Yes, if a public entity receives any Federal financial assistance from DOT whether directly or through
another DOT recipient, then the entity must also apply DOT's Section 504 requirements even if the road
alteration project at issue does not use Federal funds. See 49 CFR 27.3 (applicability of DOT's Section 504
requirements) and 27.5 (definition of"program or activity").
DOT's Section 504 disability nondiscrimination regulations are found at 49 CFR Part 27. These regulations
implement Section 504 of the Rehabilitation Act of 1973 (Section 504). In 2006, DOT updated its accessibility
standards by adopting the 2004 Americans with Disabilities Act Accessibility Guidelines (2004 ADAAG) into
its Section 504 regulations at 49 CFR 27.3 (referencing 49 CFR Part 37, Appendix A). These requirements
replaced the previously applicable ADA Standards for Accessible Design (1991) (formerly known as 1991
ADAAG). At that time, DOT's regulation adopted a modification to Section 406 of the 2004 ADAAG which
required the placement of detectable warnings on curb ramps.
The revised DOT Section 504 regulation also provided a "safe harbor" provision (similar to the ADA provision
discussed in Question 1) that applies to curb ramps that were newly constructed or altered by entities
receiving Federal financial assistance from DOT and that were in compliance with the 1991 ADAAG
requirements prior to November 29, 2006. If the "safe harbor" applies, these curb ramps are still considered
compliant and do not have to be modified to add detectable warnings unless they are altered after November
29, 2006. The DOT "safe harbor" provision is found at 49 CFR 37.9(c). DOT's Section 504 regulations (49
CFR 27.19(a)) require compliance with 49 CFR Part 37.
The Section 504 safe harbor does not apply, however, if, at the time of the road alteration project, the existing
curb ramp does not comply with the 1991 ADAAG and at that time it must be brought into compliance with
the current DOT Section 504 requirements (2004 ADAAG) including detectable warnings.
Q14: Does the Section 504 safe harbor apply to curb ramps built in compliance with 1991 ADAAG
during the time period when the requirement for detectable warnings was suspended and the
roadway is now being resurfaced where it intersects the pedestrian walkway?
A14: If the curb ramps that were built or altered prior to November 29, 2006 were fully compliant with 1991
ADAAG at the time that the detectable warnings requirements were suspended, then the DOT Section 504
sale narour appnes Lu inem anu Lne recipieni. u0es nuL nave La auu 0eieGLa0ie warnings as a resun 01 a
resurfacing project.
Q15: In addition to the obligations triggered by road resurfacing alterations, are there other title 11 or
Section 504 requirements that trigger the obligation to provide curb ramps?
Al5: In addition to the obligation to provide curb ramps when roads are resurfaced, both DOJ's title II ADA
regulation and DOT's Section 504 regulation (applicable to recipients of DOT Federal financial assistance),
require the provision of curb ramps if the sidewalk is installed or altered at the intersection, during new
construction, as a means of providing program accessibility, and as a reasonable modification under title II or
a reasonable accommodation under Section 504.
New Construction and Alterations
DOJ's title II ADA regulation provides that newly constructed or altered streets, roads, and highways must
contain curb ramps or other sloped areas at any intersection having curbs or other barriers to entry from a
street level pedestrian walkway. In addition, the regulation provides that newly constructed or altered street
level pedestrian walkways must contain curb ramps or other sloped areas at intersections to streets, roads, or
highways. See 28 CFR 35.151(i). These curb ramps must comply with the 2010 Standards.3
DOT's Section 504 Federally assisted regulation also requires the provision of curb ramps in new
construction and alterations. See 49 CFR 27.19(a) (requiring recipients of DOT financial assistance to
comply with DOJ's ADA regulation at 28 CFR Part 35, including the curb ramp requirements at 28 CFR
35.151(i)); 49 CFR 27.75 (a)(2) (requiring all pedestrian crosswalks constructed with Federal financial
assistance to have curb cuts or ramps).
Program Accessibility
Both DOJ's title II ADA regulation and DOT's Section 504 regulation require that public entities/recipients
operate each service, program, or activity so that the service, program, or activity, when viewed in its entirety,
is readily accessible to and usable by individuals with disabilities. This obligation, which is known as
providing "program accessibility," includes a requirement to evaluate existing facilities in the public right-of-
way for barriers to accessibility, including identifying non-existent or non-compliant curb ramps where roads
intersect pedestrian access routes (sidewalks or other pedestrian walkways). After completing this self-
evaluation, a public entity/recipient must set forth a plan for eliminating such barriers so as to provide overall
access for persons with disabilities. See 28 CFR 35.150, and 49 CFR 27.11(c).
Since March 15, 2012, the DOJ title II regulation requires the use of the 2010 Standards for structural
changes needed to provide program access. However, in accordance with the ADA safe harbor discussed in
Question 1, if curb ramps constructed prior to March 15, 2012 already comply with the curb ramp
requirements in the 1991 Standards, they need not be modified in accordance with the 2010 Standards in
order to provide program access, unless they are altered after March 15, 2012.
Similarly, DOT's Section 504 "safe harbor" allows curb ramps that were newly constructed or altered prior to
November 29, 2006, and that meet the 1991 ADAAG to be considered compliant.4 Elements not covered
under the sale naruor provisions may neeu to ue rnounieu to provlue program access anu snoum ue
incorporated into a program access plan for making such modifications. 49 CFR 27.11(c)(2).
Under Section 504, self-evaluations and transition plans should have been completed by December 29,
1979. Under the ADA, transition plans should have been completed by July 26, 1992, and corrective
measures should have been completed by January 26, 1995. While these deadlines have long since passed,
entities that did not develop a transition plan prior to those dates should begin immediately to complete their
self-evaluation and develop a comprehensive transition plan.
Reasonable Modification /Accommodation
In addition to alteration and program accessibility obligations, public entities may have an obligation under
title II and Section 504 to undertake curb ramp construction or alteration as a "reasonable
modification/accommodation" in response to a request by, or on behalf of, someone with a disability. Such a
request may be made to address a non-compliant curb ramp outside of the schedule provided in the public
entity's transition plan. A public entity must appropriately consider such requests as they are made. 28 CFR
35.13O(b)(7); 49 CFR 27.7(e).
1 The 2010 Standards can be found on DOJ's website at
http://wNkw.ada.gov/2010ADAstandards index.hun.
2 In 2004,the United States Architectural and Transportation Barriers Board(U.S.Access Board)
published the Americans with Disabilities Act Accessibility Guidelines(2004 ADAAG),which serve as
the basis of the current enforceable ADA standards adopted by both DOT and DOJ.
3 The 2010 Standards include a provision on equivalent facilitation that allows covered entities to use
other designs for curb ramps if such designs provide equal or greater access. See section 103 of the 2010
Standards.
3 The DOT"safe harbor"provision is found at 49 CFR 37.9(c). DOT's Section 504 regulations(49 CFR
27.19(a))require compliance with 49 CFR Part 37.
The Americans with Disabilities Act authorizes the Department of Justice (the Department) to provide
technical assistance to individuals and entities that have rights or responsibilities under the Act. This
document provides informal guidance to assist you in understanding the ADA and the Department's
regulations.
This guidance document is not intended to be a final agency action, has no legally binding effect, and may be
rescinded or modified in the Department's complete discretion, in accordance with applicable laws. The
Department's guidance documents, including this guidance, do not establish legally enforceable
responsibilities beyond what is required by the terms of the applicable statutes, regulations, or binding judicial
precedent.
Deccember 1,2015
Public Right-of-Way
ADA (Americans with Disabilities Act)
Self-Evaluation and Transition Plan
ON
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Appendix E
Public Engagement Strategy and Findings
December 2024
Prepared by
' Transportation Solutions
INNOVATIVE I PRACTICAL I EQUITABLE
Appendix E will be available
after the public comment period ends
For more information, see Chapter E
of the Jefferson County PROW ADA Transition Plan